Woods v. Kuhlmann’s Empirical Analysis
977 F.2d 74 · 1992
Citation profile
41 federal appellate · 3 district · 33 state decisions
How this case has been cited
Cited by 105 later decisions — most recently June 2024 · most notably State v. Drummond (2006), Ernest Sutton Bell v. Mack Jarvis Robert Smith (2000)
41 federal appellate · 3 district · 33 state decisions — followed in 17 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. § 2254 (Antiterrorism and Effective Death Penalty Act of 1996)
Relies on Waller v. Georgia · Press-Enterprise Company v. Superior Court of California Riverside County · Gregory v. United States · Reavis v. Antinore · Hopkins v. Arizona Department of Real Estate
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 105 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“implicate the same secrecy and fairness concerns that a total closure does.”
5 later decisions quote this exact passage · from the majority“[T]he Ninth, Tenth and Eleventh Circuits .. . have concluded that when a trial judge orders a partial, as opposed to a total, closure of a court proceeding at the request of one party, a 'substantial reason' rather than Waller's 'overriding interest' will justify the closure.... We agree.”
4 later decisions quote this exact passage · from the majority“[1] the party seeking to close the hearing must advance an overriding interest that is likely to be prejudiced, [2] the closure must be no broader than necessary to protect that interest, [3] the trial court must consider reasonable alternatives to closing the proceeding, and [4] it must make findings adequate to support the closure.”
3 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.