Butler v. Aiken’s Empirical Analysis
846 F.2d 255 · 1988
Citation profile
7 federal appellate · 1 district · 5 state decisions
How this case has been cited
Cited by 16 later decisions (1 by the Supreme Court) — most recently September 2001
7 federal appellate · 1 district · 5 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 28 U.S.C. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996) · 28 U.S.C. § 636
Relies on Miranda v. State of Arizona Vignera · Edwards v. Arizona · Escobedo v. Illinois · Colorado v. Spring · Solem v. Stumes
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As the Supreme Court has observed, the "prophylactic rule" adopted in Edwards "has only a tangential relation to truth-finding. ” It was articulated as a reflection of the Court's belief that additional procedural safeguards were needed to protect an accused's preexisting right to request counsel during custodial interrogation. Such "safeguards" by their inherent nature are a judicial response to specific and identifiable conditions that undermine the perceived integrity of the legal system. In Miranda , for example, the Court sought to insure that statements made by an accused while in the unavoidably coercive atmosphere of custodial interrogation could reasonably be viewed as truly voluntary. In Edwards , the Court's concern lay with police conduct that might badger an accused into abandoning a previously invoked right. We fail to see how the actions of the Charleston police could fall within the intent of the Court in Edwards . There is no suggestion that [the defendant's] arrest on the assault charges was a sham intended to make him available for questioning upon a more serious offense. Neither was there "reinterrogation" on the same offense that might have sent mixed signals regarding his continuing right to request counsel. Certainly, if [the defendant] had been released on bond and then rearrested an hour later on murder charges, the authorities would have been permitted to engage in proper interrogation. We see no reason for a different result simply because the custo”
1 later decision quote this exact passage · from the majority““a properly initiated interrogation on [an] entirely different chargef ] [did] not intrude into an accused’s previously invoked rights but [instead] offers [the] accused an opportunity to weigh his rights intelligently in light of changed circumstances. When, as occurred in this case, the accused then freely waives any constitutional right to counsel and provides voluntary statements of an incriminating nature, there is no justification for undermining the search for [the] truth by suppressing those statements.” Butler, 846 F.2d at 259 .”
1 later decision quote this exact passage · from the majority“after a person in custody has expressed his desire to deal with the police only through counsel, he 'is not subject to further interrogation by the authorities until counsel has been made available to him, unless the accused himself initiates further communication, exchanges, or conversations with the police,'”
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.