United States v. Watson’s Empirical Analysis
894 F.2d 1345 · 1990
Citation profile
33 federal appellate · 1 district · 17 state decisions
How this case has been cited
Cited by 57 later decisions — most recently June 2019 · most notably United States v. York (1991), United States v. Johnson (1994)
33 federal appellate · 1 district · 17 state decisions — followed in 10 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 21 U.S.C. § 841 (§ 401 of the Controlled Substances Act)
Relies on Massiah v. United States · Moran v. Burbine · Maine v. Moulton · Kuhlmann v. Wilson · United States v. Henry
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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“refuse[d] to extend the rule in Massiah and Henry to situations where an individual, acting on his own initiative, deliberately elicits incriminating information.”
2 later decisions quote this exact passage · from the majority“temporal (as well as the logical) relationship between a defendant's later act and his earlier state of mind attenuates the relevance of such proof,”
2 later decisions quote this exact passage · from the majority“It is established in the case law that in order for there to be a Massiah -type violation of a defendant's sixth amendment right to counsel, the person eliciting the incriminating information must be acting as a government agent. ... . We join the circuits that have expressly "refuse[d] to extend the rule in Massiah and Henry to situations where an individual, acting on his own initiative, deliberately elicits incriminating information."”
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.