Cross v. United States’s Empirical Analysis
893 F.2d 1287 · 1990
Citation profile
54 federal appellate · 20 state decisions
How this case has been cited
Cited by 124 later decisions (1 by the Supreme Court) — most recently March 2025 · most notably George Smith Warden v. Lee Robbins (2000), 15 Cal. 4th 1 - People v. Marshall (1997)
54 federal appellate · 20 state decisions — followed in 12 states
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. § 2255 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Strickland v. Washington · Faretta v. California · Murray v. Carrier · Bonner v. City of Prichard · United States v. Frady
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 124 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[A]n individual does not have a right to hybrid representation. . . . Rather, the decision to permit a defendant to proceed as co-counsel rests in the sound discretion of the trial court.' Cross v. United States , 893 F.2d 1287 , 1291-92 (11th Cir.), cert. denied, 498 U.S. 849 , 111 S.Ct. 138 , 112 L.Ed.2d 105 (1990).”
4 later decisions quote this exact passage · from the majoritye.g. Minor v. State · Whitehead v. State“[A] trial court can commit reversible constitutional error by either improperly granting a request to proceed pro se--and thereby depriving the individual of his right to counsel--or by denying a proper assertion of the right to represent oneself, and thereby violating Faretta.”
3 later decisions quote this exact passage · from the majority“exploit this difficult constitutional area by making ambiguous self-representation claims to inject error into the record.”
2 later decisions 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.