Fitzpatrick v. Wainwright’s Empirical Analysis
800 F.2d 1057 · 1986
Citation profile
38 federal appellate · 53 state decisions
How this case has been cited
Cited by 125 later decisions — most recently April 2022 · most notably United States v. Moya-Gomez (1988), 48 Cal. 3d 1194 - People v. Bloom (1989)
38 federal appellate · 53 state decisions — followed in 13 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 Johnson v. Zerbst · Faretta v. California · Gideon v. Wainwright · Powell v. State of Alabama Patterson · Bonner v. City of Prichard
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 125 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The ultimate test is not the trial court's express advice, but rather the defendant's understanding.”
19 later decisions quote this exact passage · from the majoritye.g. Coughlin v. State · Osbey v. State“1) the defendant’s age, health, and education; 2) the defendant’s contact with lawyers prior to trial; 3) the defendant’s knowledge of the nature of the charges and possible defenses and penalties; 4) the defendant’s understanding of the rules of evidence, procedure and courtroom decorum; 5) the defendant’s experience in criminal trials; 6) whether standby counsel was appointed and, if so, the extent to which standby counsel aided in the trial; 7) any mistreatment or coercion of the defendant; and 8) whether the defendant was attempting to manipulate the trial.”
6 later decisions quote this exact passage · from the majority“'Although the Supreme Court in Faretta states that a defendant should be made aware of the dangers and disadvantages of self-representation, the Supreme Court does not require a specific colloquy between the trial judge and the defendant.”
6 later decisions 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.