United States v. McElroy’s Empirical Analysis
697 F.2d 459 · 1982
Citation profile
20 federal appellate · 1 district · 3 state decisions
How this case has been cited
Cited by 31 later decisions — most recently December 2018 · most notably United States v. Scarpa (1990), United States v. Howell (2000)
20 federal appellate · 1 district · 3 state decisions
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
Applies 18 U.S.C. § 3500 · 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act) · 21 U.S.C. § 846 (§ 406 of the Controlled Substances Act)
Relies on Miranda v. State of Arizona Vignera · Brady v. State of Maryland · Edwards v. Arizona · Doyle v. Ohio · Bullock v. United States
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he government's failure to disclose prejudiced McElroy because it kept from his counsel's eyes possible grounds for a suppression motion. We reject as unrealistic the government's argument that appellate relief must be denied because counsel could have obtained from McElroy the information necessary to make the motion. The defendant in a criminal case often mistrusts his counsel who, in most instances, has been assigned and not chosen, or believes that his counsel will best defend him if he is kept ignorant of the facts. Even a defendant who cooperates with his counsel cannot always remember all of the relevant facts, or realize the importance to his defense of seemingly inconsequential police actions. Defense lawyers, as a result, often learn much more about what has happened from government discovery, formal and informal, than they do from their clients. This fact surely is one of the reasons behind the adoption of Rule 16....”
2 later decisions quote this exact passage · from the majority“reflects the drafters' studied conclusion that pretrial discovery of oral statements serves significantly to protect the defendant's right to a fair trial. Pretrial discovery prevents the defendant from being unfairly surprised with his statements at trial and enhances the ability of defense counsel to suppress inadmissible statements. In particular, statements obtained in violation of Miranda are most likely to be identified and suppressed if they are made available to counsel prior to trial. In short, Rule 16 discovery is an important guarantor of simple fairness to defendants.”
2 later decisions quote this exact passage · from the majority“Rule 16 thus does not cover oral statements unrelated to the crime charged or completely separate from the Government's trial evidence.”
2 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.