Murphy v. Holland’s Empirical Analysis
776 F.2d 470 · 1985
Citation profile
40 federal appellate · 2 district · 2 state decisions
How this case has been cited
Cited by 52 later decisions — most recently February 2024 · most notably United States v. Headspeth (1988), United States v. Adkins (1991)
40 federal appellate · 2 district · 2 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 Johnson v. Zerbst · Edwards v. Arizona · Rhode Island v. Innis · Massiah v. United States · Cupp v. Naughten
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 52 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Absent some form of interrogation or conduct designed to elicit incriminating responses, whether direct or disguised, neither the fifth nor the sixth amendment can be invoked to shield the accused from the effects of his uncounseled confession.”
2 later decisions quote this exact passage · from the majority“The term reasonable doubt itself has a self-evident meaning comprehensible to the lay juror. That subjective meaning is hardly susceptible to significant improvement by judicial efforts to define reasonable doubt with unattainable precision. Instead of improvement, the most likely outcome of attempts to define reasonable doubt is unnecessary confusion and a constitutionally impermissible lessening of the required standard of proof.... To protect the accused’s due process rights and avoid supplying the grounds for unnecessary constitutional challenges ... the wisest course for trial courts to take is to avoid defining reasonable doubt in their instructions unless specifically requested to do so by the jury.”
1 later decision quote this exact passage · from the majority“by itself so infected the entire trial that the resulting conviction violates due process,”
1 later decision quote this exact passage · from the majoritye.g. Nickerson v. Ta Lee
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.