United States v. Clark’s Empirical Analysis
712 F.2d 299 · 1983
Citation profile
16 federal appellate · 4 district · 4 state decisions
How this case has been cited
Cited by 34 later decisions — most recently September 2023 · most notably United States v. Byrd (1984), United States v. Hamilton (1994)
16 federal appellate · 4 district · 4 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. § 2113 · 18 U.S.C. § 657
Relies on Trammel v. United States · Streeter v. United States · Butz v. Hein · United States v. Barlow · O'Callaghan v. Sheldon
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although it is true that Van Drunen created the premarriage acts exception because of concern with collusive marriages, there is nothing in the opinion to suggest that the exception applies only when there is evidence presented of a collusive marriage. By imposing a general rule that the privilege does not cover premarriage acts, courts can avoid mini-trials on the issue of the sincerity of the parties in getting married.”
3 later decisions quote this exact passage“did not justify assuring a criminal that he or she could enlist the aid of a spouse in a criminal enterprise without fear that ... the criminal was creating another potential witness,”
2 later decisions quote this exact passage“[f]urthermore, at least two other circuits have recognized the joint participants exception to a similar marital privilege, the privilege against one spouse testifying as to the confidential communications of the other.”
1 later decision quote this exact passage
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.