United States v. Liu’s Empirical Analysis
960 F.2d 449 · 1992
Citation profile
37 federal appellate · 1 district · 9 state decisions
How this case has been cited
Cited by 56 later decisions — most recently March 2024 · most notably United States v. Puig-Infante (1994), United States v. Pofahl (1993)
37 federal appellate · 1 district · 9 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. § 201 (Bank Bribery Amendments) · 18 U.S.C. § 922 (Brady Handgun Violence Prevention Act)
Relies on Mathews v. United States · Benjamin v. United States · CPC International Inc. v. Dimmitt Agri Industries, Inc. · United States v. Gant · 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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Rule 803(3) ] , by its own terms excepts from the ban on hearsay such statements as might have been made by Cohen of his then existing state of mind or emotion, but expressly excludes from the operation of the rule a statement of belief to prove the fact believed.... But the state-of-mind exception does not permit the witness to relate any of the declarant’s statements as to why he held the particular state of mind, or what he might have believed that would have induced the state of mind. If the reservation in the text of the rule is to have any effect, it must be understood to narrowly limit those admissible statements to declarations of condition — “I’m scared” — and not belief — “I’m scared because Galkin threatened me.””
4 later decisions quote this exact passage · from the majority“(1) that defendant was under an unlawful and ‘present, imminent, and impending (threat) of such a nature as to induce a well-grounded apprehension of death or serious bodily injury.’; (2) that defendant had not ‘recklessly or negligently placed himself in a situation in which it was probable that he would be (forced to choose the criminal conduct)’; (3) that defendant had no ‘reasonable legal alternative to violating the law; a chance both to refuse to do the criminal act and also to avoid the threatened harm’, and (4) ‘that a direct causal relationship may be reasonably anticipated between the (criminal) action taken and the avoidance of (threatened) harm.’”
4 later decisions quote this exact passage · from the majority“It is clear that the jury should be informed that the [duress] defense is available if the defendant proves that he, or a member of his family, was under a present, imminent, or impending threat of death or serious bodily injury.”
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.