Guzman v. Scully’s Empirical Analysis
80 F.3d 772 · 1996
Citation profile
27 federal appellate · 1 district · 16 state decisions
How this case has been cited
Cited by 71 later decisions — most recently June 2024 · most notably Ernest Sutton Bell v. Mack Jarvis Robert Smith (2000), Thomas Garcia v. Hazel Lewis Hale Creek Correctional Facility (1999)
27 federal appellate · 1 district · 16 state decisions — followed in 11 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 In re Oliver · Waller v. Georgia · Press-Enterprise Company v. Superior Court of California Riverside County · Press-Enterprise Company v. Superior Court of California for County of Riverside · Dennis v. Dennis
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 71 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The exclusion of courtroom observers, especially a defendant's family members and friends, even from part of a criminal trial, is not a step to be taken lightly.”
3 later decisions quote this exact passage“conduct[] an inquiry of the prosecution witness on whose behalf the closure request was made.”
3 later decisions quote this exact passage“The trial court based its decision solely upon representations made by the prosecutor that [the prosecution witness] felt intimidated by the presence of these four women in the courtroom. The trial court, however, did not inquire of the witness whether he in fact felt intimidated nor whether his fear, if genuinely held, was sufficiently well-founded to constitute an “overriding interest” within the meaning of Waller , or at least a “substantial interest” within the meaning of Woods . Indeed, the trial court made no inquiry whatsoever. Although this Circuit has not required that a separate hearing must always be held before the courtroom doors may be closed, separate hearing must always be held before the courtroom doors may be closed, the lack of such a hearing is relevant to the lawfulness of any closure____ Even more disturbing is the fact that when defense counsel pointed out that two of the women were not related to [the other witness], as the prosecution had alleged, but were instead related to the defendant, the trial court still did not make any inquiry to ascertain the relevant facts. If that inquiry had confirmed defense counsel’s assertion that two of the women were part of [defendant’s] family or at least his friends, then the trial court would have been obliged to give significant weight to this circumstance in determining whether closure was warranted.”
1 later decision quote this exact passage
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.