Quadrini v. Clusen’s Empirical Analysis
864 F.2d 577 · 1989
Citation profile
20 federal appellate · 4 state decisions
How this case has been cited
Cited by 33 later decisions — most recently March 2025 · most notably United States v. Rodriguez (1989), Chichakly v. United States (1991)
20 federal appellate · 4 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)
Relies on Miranda v. State of Arizona Vignera · Johnson v. Zerbst · Edwards v. Arizona · Gerstein v. Pugh · Kirby v. Illinois
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]s a general matter, then, an accused who is [given Miranda warnings] has been sufficiently apprised of the nature of his Sixth Amendment rights, and of the consequences of abandoning those rights, so that his waiver on this basis will be considered a knowing and intelligent one.”
2 later decisions quote this exact passage · from the majority““The petitioner argues extensively that the sixth amendment should impose a heavier burden on the state than that under Miranda to prove waiver of a defendant’s right to counsel. He contends that this heavier burden ‘may require greater explanation of the rights being relinquished and/or a more clearly expressed waiver than that mandated by Miranda.’ In support of this argument the petitioner substantially relies on United States v. Mohabir, 624 F.2d 1140 , 1151-53 (2nd Cir.1980), in which the Second Circuit imposed a requirement that before a valid waiver can be executed, a federal judicial officer must explain to the accused the significance of the sixth amendment right to counsel. The petitioner ignores the fact that this court has previously considered the Mohabir decision and held: ‘We decline to impose a rigid test for determining when the accused validly has waived his sixth amendment right to counsel. Rather, whether the accused has waived his sixth amendment right depends on the individual circumstances of each case.’ Robinson v. Percy, 738 F.2d 214 , 222 (7th Cir.1984) (citing United States v. Springer, 460 F.2d 1344 , 1350-52 (7th Cir.), cert. denied, 409 U.S. 873 , 93 S.Ct. 205 , 34 L.Ed.2d 125 (1972)).””
1 later decision quote this exact passage · from the majority““The Supreme Court held in Brewer v. Williams, 430 U.S. 387 , 97 S.Ct. 1232 , 51 L.Ed.2d 424 (1977), that absent a valid waiver, confessions elicited from an accused after the right to counsel has attached violate the sixth and fourteenth amendments if they were elicited outside the presence of counsel. This standard requires us to answer three questions: (1) whether the right to counsel had attached at the time of the confession; (2) if so, whether the accused executed a valid waiver of his right to counsel; and (3) absent a valid waiver, whether the police conduct violated the accused’s right to counsel.””
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.