Public-domain · open source
OpenJurist
← 828 F.3d 1337 - In re Baptiste

In re Baptiste’s Empirical Analysis

828 F.3d 1337 · 2016

Citation profile

28
cited by 28 later decisions
1
cited 1 times by the Supreme Court
January 2026
most recently cited

19 federal appellate ·

Relationships

Applies 18 U.S.C. § 924 · 28 U.S.C. § 2244 (Antiterrorism and Effective Death Penalty Act of 1996) · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)

Relies on Melvin Tyler v. Burl Cain Warden · Welch v. United States · United States v. Amedeo · Triestman v. United States · Charles v. Chandler

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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Baptiste was construing ... 28 U.S.C. § 2244 (b)(1), which says any “claim presented in a second or successive habeas corpus application under section 2254 that was presented in a prior application shall be dismissed.” Of course, [ ] § 2255 motions ... are filed by federal prisoners [and] § 2255 motions are certainly not brought “under section 2254,” which governs petitions filed by state prisoners. But the Baptiste panel ruled that even though § 2244(b)(1) does not mention § 2255 motions, it applies to them anyway, since “it would be odd [] if Congress had intended to allow federal prisoners” to do something state prisoners can’t do.”
    4 later decisions quote this exact passage
  2. “it would be odd indeed if Congress had intended to allow federal prisoners to refile precisely the same non-meritorious motions over and over again while denying that right to state prisoners.”
    3 later decisions quote this exact passage
  3. “applications for leave to file a second or successive § 2255 motion presenting the same claims we have already rejected on their merits in a previous application.”
    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.