United States v. Wright’s Empirical Analysis
797 F.2d 245 · 1986
Citation profile
32 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 46 later decisions — most recently October 2015 · most notably United States v. Collins (1994), Jund v. Town Hempstead (1991)
32 federal appellate · 1 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 18 U.S.C. § 1951 (Hobbs Act)
Relies on Stirone v. United States · S.S. Zoe Colocotroni v. Puerto Rico · United States v. James · Exxon Corp. v. Department of Revenue of Wisconsin · United States v. Culbert
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A conviction under the Hobbs Act may be sustained by a finding that a public official has taken a fee, unlawfully, under color of his public office, in return for performance or nonperformance of an official act.”
2 later decisions quote this exact passage · from the majority“[t]here is no requirement that threat, force, or duress be proved when the defendant is a public officer,”
2 later decisions quote this exact passage · from the majority““The ‘quid pro quo’ found by the trial judge was dismissal by Armstrong of an outstanding DWI prosecution against a personal injury client of Wright’s, accompanied by payment of a referral fee by Wright to Armstrong when the client’s case settled. In order to sustain the Hatch [sic] Act charges, the court had to find that the public official had some discretion to act or not to act in the performance of his duties, which official action or inaction could be influenced by payment of a bribe. Whether the dismissal by Armstrong of an outstanding first-offense DWI prosecution grounded on a stale arrest warrant and an inadmissible intoxication test constitutes the requisite ‘quid pro quo’ of a Hatch [sic] Act conviction appears highly debatable. This close legal call sparked a vigorous dissent from Judge Brown of the U.S. Fifth Circuit: ‘Had the judge ... realized that the [DWI] prosecution was indeed barred — it is clear [he] could not have found these attorneys guilty beyond a reasonable doubt.’ In dissent Judge Brown succinctly points out that ‘[w]ith Armstrong’s valid argument for not prosecuting [the DWI], the government’s entire case unravels.’ The authorities articulated for Armstrong’s decision to dismiss the DWI prosecution are impressive and within the mainstream of accepted jurisprudence concerning such matters.” (Citations omitted).”
1 later decision quote this exact passage · from the dissent
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.