Jamison v. Al Lockhart’s Empirical Analysis
975 F.2d 1377 · 1992
Citation profile
17 federal appellate · 1 district ·
How this case has been cited
Cited by 29 later decisions (2 by the Supreme Court) — most recently November 2014 · most notably Maples v. Thomas (2012), Garcia v. Bunnell (1994)
17 federal appellate · 1 district ·
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
Relies on Strickland v. Washington · Coleman v. Thompson · Wainwright v. Sykes · Townsend v. Sain · Murray v. Carrier
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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Attorney error that constitutes ineffective assistance of counsel is cause, however. This is not because, as Coleman contends, the error is so bad that “the lawyer ceases to be an agent of the petitioner.” In a case such as this, where the alleged attorney error is inadvertence in failing to file a timely notice, such a rule would be contrary to well-settled principles of agency law. Rather, as Carrier explains, “if the procedural default is the result of ineffective assistance of counsel, the Sixth Amendment itself requires that responsibility for the default be imputed to the State.” In other words, it is not the gravity of the attorney’s error that matters, but that it constitutes a violation of petitioner’s right to counsel, so that the error must be seen as an external factor, i.e., “imputed to the State.””
1 later decision quote this exact passage · from the majoritye.g. Wooten v. Norris“The cause of the default could be certain actions or decisions of [trial counsel] flowing from his divided loyalties. The cause of these actions or decisions would thus be external, and perhaps directly contrary, to the defense of Jamison in this case. The cause would satisfy the standard enunciated in Muiray because it arose from such an external source and not from the trial strategy or tactics of Wright acting in Jamison's defense. That conflicting loyalties may have influenced strategies and tactics does not defeat the conclusion that the conflict of interest was an objective factor external to the defense.”
1 later decision quote this exact passage · from the majoritye.g. Wooten v. Norris
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.