Brown v. Rios’s Empirical Analysis

Citation profile

10 federal appellate ·

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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(1) that he relies on “not a constitutional case, but a statutory-interpretation case, so [that he] could not have invoked it by means of a second or successive section 2255 motion,” (2) that the new rule applies retroactively to cases on collateral review and could not have been invoked in his earlier proceeding, and (3) that the error is “grave enough ... to be deemed a miscarriage of justice corrigi-ble therefore in a habeas corpus proceeding,” such as one resulting in “a conviction for a crime of which he was innocent.””

   2 later decisions quote this exact passage · from the majority
   e.g. Prevatte v. Merlak · Jahns v. Julian

2. “First, the prisoner must show that he relies on a “statutory-interpretation case,” rather than a “constitutional case.” Second, the prisoner must show that he relies on a retroactive decision that he could not have invoked in his first § 2255 motion. “The third condition is that [the] sentence enhancement ... have been a grave enough error to be deemed a miscarriage of justice corri-gible therefore in a habeas corpus proceeding.””

   2 later decisions quote this exact passage · from the majority
   e.g. Light v. Caraway · Jahns v. Julian

3. “a conviction for a crime of which he was innocent.”

   1 later decision quote this exact passage · from the majority
   e.g. Jahns v. Julian