United States v. Under Seal’s Empirical Analysis
884 F.2d 124 · 1989
Citation profile
12 federal appellate · 2 district · 2 state decisions
How this case has been cited
Cited by 35 later decisions — most recently August 2017 · most notably Grand Jury Proceedings Thursday Special Grand Jury September Term United States v. Under Seal (1994), Sandberg v. Virginia Bankshares, Inc. (1992)
12 federal appellate · 2 district · 2 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. § 6003
Relies on Kerr v. United States Dist. Court for Northern Dist. of Cal. · Clark v. United States · In re Sealed Case · Grand Jury Proceedings Fmc Corporation · In Re John Doe Corporation
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“absent a clear showing of abuse of discretion.”
3 later decisions quote this exact passage“The crime-fraud exception to the attorney-client privilege provides that a client's communications with an attorney will not be privileged if made for the purpose of committing or furthering a crime or fraud.... In order to overcome [an asserted] privilege, the government must make a prima facie showing that the communications sought fall within the crime-fraud exception.”
1 later decision quote this exact passage“in instances where the government did not intend to reveal the grand jury materials to the witness, in camera proceedings were appropriate to protect the government's interests in secrecy.”
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.