Public-domain · open source
OpenJurist
← 735 F.2d 1242 - Jarrell v. Balkcom

Jarrell v. Balkcom’s Empirical Analysis

735 F.2d 1242 · 1984

Citation profile

93
cited by 93 later decisions
12
states following
September 2018
most recently cited

37 federal appellate · 4 district · 25 state decisions

How this case has been cited

Cited by 93 later decisions — most recently September 2018 · most notably Wilson v. Attaway (1985), McCleskey v. Kemp (1985)

37 federal appellate · 4 district · 25 state decisions — followed in 12 states

4401984199020002010decided

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 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)

Relies on Strickland v. Washington · Brady v. State of Maryland · Payton v. New York · Wainwright v. Sykes · Jackson v. Denno

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

  1. “suspects in the sense that the investigation actually focused on them.”
    4 later decisions quote this exact passage · from the majority
  2. ““Under the circumstances of this case, we do not view a confession given less than four hours after the issuance of Miranda warnings inadmissible because of the failure to reissue the warnings. Although Jarrell was not technically in custody until he was arrested, he was a suspect from the moment he received his warnings. The record reflects that the warnings given were complete and that Jarrell understood them. Cf. Edwards v. Indiana, 412 N.E.2d 223, 225-26 (Ind.1980) (where defendant, not yet a suspect, was given orally his Miranda warnings and record contained no evidence of content of oral advisement, confession given 5 hours later when defendant had become a suspect not admissible). Furthermore, the fact that Jarrell confessed to a state officer (Blannott) other than the one who administered the Miranda warnings (Bishop), does not render the warnings insufficient, especially since, before interrogating Jarrell, Blannott asked Bishop in Jarrell’s presence whether petitioner had received his Miranda warnings. (T.T. 545). See State v. Gallagher, 36 Ohio App.2d [2]9, 301 N.E.2d 888 (1973) (change from one state interrogator to another insufficient break to require fresh warnings). Cf. United States v. Hopkins, 433 F.2d 1041 (5th Cir.1970), cert. denied, 401 U.S. 1013 , 91 S.Ct. 1252 , 28 L.Ed.2d 550 (1971) (change from state police officer questioning defendant about state crime to federal officer questioning about federal crime; no new warnings required); Mitchell v. State,”
    3 later decisions quote this exact passage · from the majority
  3. “[a] finding of cause must be based on a determination that a miscarriage of justice was suffered and no strategic advantage was gained by failing to comply with the procedural rule.”
    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.