Martin v. Wainwright’s Empirical Analysis
770 F.2d 918 · 1985
Citation profile
97 federal appellate · 5 district · 58 state decisions
How this case has been cited
Cited by 204 later decisions (1 by the Supreme Court) — most recently April 2015 · most notably Arizona v. Fulminante (1991), Clark v. Murphy (2003)
97 federal appellate · 5 district · 58 state decisions — followed in 22 states
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 Miranda v. State of Arizona Vignera · Chapman v. State of California · Johnson v. Zerbst · Bonner v. City of Prichard · Witherspoon v. Illinois
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 204 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"In Elstad , the Court began by considering whether, and under what circumstances, the failure to administer Miranda warnings prior to a confession `taints,' under the `fruit of the poisonous tree' doctrine, a subsequent confession. The Court noted that the `fruit of the poisonous tree' doctrine applies only to constitutional violations. Id. at [306], 105 S.Ct. at 1291 . The Miranda exclusionary rule, however, `sweeps more broadly than the Fifth Amendment itself. It may be triggered even in the absence of a Fifth Amendment violation. The Fifth Amendment prohibits use by the prosecution in its case in chief only of compelled testimony.' Id. at [307], 105 S.Ct. at 1292 (footnote omitted; emphasis in original). Miranda creates a `presumption of compulsion,' which, `though irrebuttable for purposes of the prosecution's case in chief, does not require that the statements and their fruits be discarded as inherently tainted.' Id. The Court concluded: "It is an unwarranted extension of Miranda to hold that a simple failure to administer the warnings, unaccompanied by any actual coercion or other circumstances calculated to undermine the suspect's ability to exercise his free will so taints the investigatory process that a subsequent voluntary and informed waiver is ineffective for some indeterminate period. Though Miranda requires that the unwarned admission must be suppressed, the admissibility of any subsequent statement should turn in these circumstances solely on whether it is kn”
3 later decisions quote this exact passage · from the majority“[i]f the individual indicates in any manner, at any time prior to or during questioning, that he wishes to remain silent, the interrogation must cease.”
3 later decisions quote this exact passage · from the majority“We see no reason to apply a different rule to equivocal invocations of the right to cut off questioning.”
3 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.