United States v. Eagle Elk’s Empirical Analysis
820 F.2d 959 · 1987
Citation profile
9 federal appellate · 7 state decisions
How this case has been cited
Cited by 18 later decisions — most recently June 2025
9 federal appellate · 7 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. § 1111 · 18 U.S.C. § 1153 · 18 U.S.C. § 2 · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on United States v. Gipson · United States v. Mastelotto · United States v. Peterson · United States v. Elk · Fryer v. Nix
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Under the sixth amendment, a criminal defendant in federal court has a non-waivable right to a unanimous jury verdict. ... In the present case, the jury returned a unanimous verdict finding Eagle Elk guilty under 18 U.S.C. § 2 (a), which was quoted in the trial court’s instructions. The statute makes an aider or abettor in an offense against the United States “punishable as a principal.” Even if the jury was divided on whether Eagle Elk committed the principal crime or aided or abetted in its commission, there can be no question that the illegal act was murder.”
1 later decision quote this exact passage · from the majoritye.g. State v. Miller“substantial agreement as to the nature of the defendant's guilty act”
1 later decision 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.