United States v. Gray’s Empirical Analysis
878 F.2d 702 · 1989
Citation profile
59 federal appellate · 25 district · 7 state decisions
How this case has been cited
Cited by 154 later decisions — most recently June 2025 · most notably Sanders v. Ratelle (1994), Silva v. Woodford (2002)
59 federal appellate · 25 district · 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. § 922 (Brady Handgun Violence Prevention Act) · 18 U.S.C. § 924 · 28 U.S.C. § 1291 · 28 U.S.C. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Strickland v. Washington · United States v. Agurs · Kimmelman v. Morrison · Michel v. State of Louisiana Poret · United States v. Valenzuela-Bernal
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 154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]neffectiveness is generally clear in the context of complete failure to investigate because counsel can hardly be said to have made a strategic choice when s/he [sic] has not yet obtained the facts on which such a decision could be made.”
5 later decisions quote this exact passage · from the concurrence“'strategic choices made after thorough investigation of law and facts relevant to plausible options are virtually unchallengeable; and strategic choices made after less than complete investigation are reasonable precisely to the extent that reasonable professional judgments support the limitations on investigation.'”
4 later decisions quote this exact passage · from the concurrence“(1) that counsel's representation fell below an objective standard of reasonableness; and (2) that there is a reasonable probability that, but for counsel's error, the result would have been different.”
4 later decisions quote this exact passage · from the concurrence
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.