Proffitt v. Wainwright’s Empirical Analysis
685 F.2d 1227 · 1982
Citation profile
87 federal appellate · 2 district · 68 state decisions
How this case has been cited
Cited by 246 later decisions (3 by the Supreme Court) — most recently November 2022 · most notably Lambrix v. Singletary (1997), State v. Cooey (1989)
87 federal appellate · 2 district · 68 state decisions — followed in 23 states
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Jackson v. Virginia · Johnson v. Zerbst · Morrissey v. Brewer · Wainwright v. Sykes · Townsend v. Sain
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 246 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“be lost by consent or at times even by misconduct.”
5 later decisions quote this exact passage · from the dissent“' "A defendant's right to be present at all stages of a criminal trial derives from the confrontation clause of the Sixth Amendment and the due process clause of the Fourteenth Amendment. Illinois v. Allen , 397 U.S. 337 , 338, 90 S.Ct. 1057 , 1058, 25 L.Ed. 2d 353 (1970) ; Hopt v. Utah , 110 U.S. 574 , 579, 4 S.Ct. 202 , 204, 28 L.Ed. 262 (1884). This right extends to all hearings that are an essential part of the trial-i.e., to all proceedings at which the defendant's presence 'has a relation, reasonably substantial, to the fullness of his opportunity to defend against the charge.' Snyder v. Massachusetts , 291 U.S. 97 , 105-06, 54 S.Ct. 330 , 332, 78 L.Ed. 674 (1934). Compare Hopt v. Utah , supra (defendant has right to be present at empaneling of jurors); Bartone v. United States , 375 U.S. 52 , 84 S.Ct. 21 , 11 L.Ed. 2d 11 (1963) (court cannot impose sentence in absence of defendant); with United States v. Howell , 514 F.2d 710 (5th Cir. 1975) ; cert. denied , 429 U.S. 838 , 97 S.Ct. 109 , 50 L.Ed. 2d 105 (1976) (no right to be present at in camera conference concerning attempted bribe of juror); United States v. Gradsky , 434 F.2d 880 (5th Cir.1970), cert. denied , 409 U.S. 894 , 93 S.Ct. 203 , 34 L.Ed. 2d 151 (1972) (right to presence does not extend to evidentiary hearing on suppression motion.)”
4 later decisions quote this exact passage · from the concurrence“belief that he could not, under the Florida statute, introduce evidence of mitigating factors not listed in [the statute] was entirely reasonable.”
3 later decisions quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.