Mealer v. Jones’s Empirical Analysis
741 F.2d 1451 · 1984
Citation profile
10 federal appellate · 1 district · 5 state decisions
How this case has been cited
Cited by 23 later decisions (1 by the Supreme Court) — most recently July 2014
10 federal appellate · 1 district · 5 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 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Moses H. Cone Memorial Hospital v. Mercury Construction Corp. · Ohio Bureau of Employment Services v. Hodory · Massiah v. United States · Harrington v. California · Sumner v. Mata
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But the facts of this case demonstrate the fallacy of automatically treating as a similar windfall to the government any information it obtains during a “new crimes” investigation. The “new crime” under investigation here was Mealer’s attempt to suborn perjury at the trial on his pending indictment. That crime was intimately related to the pending indictment, and the government must have known that any statements made in the course of suborning perjury would nec essarily incriminate Mealer on the murder charge as well. Under the circumstances, we decline to assume that merely because the government was'put on notice by appellant that he contemplated a new crime, in empowering its agent to investigate that new crime the government lacked all designs to elicit information concerning the old. Indeed, given that the nature of the new crime proposed also put the government on notice that any discussion between Mealer and Gaudet would almost certainly incriminate Mealer on the old crime as well, we view this, if anything, as an even stronger case than Beatty for finding a violation of defendant’s Sixth Amendment rights.”
1 later decision quote this exact passage · from the majority“The question posed here is whether incriminating statements that concern an already indicted offense may, notwithstanding Massiah, be introduced at trial on that offense, if they were obtained coincidentally in the course of an investigation into a new crime for which the defendant has not been indicted.”
1 later decision 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.