Case Citator › Remmer v. United States

Remmer v. United States

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
347 U.S. 227
Decided
Confirmed treatments
1
Flagged citations read
47 of 47
Citing cases (total)
47
Treatment dates
2026
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Remmer v. United States was limited by the Sixth Circuit, which required proof of actual bias for the alleged outside jury interference before it; the 1 confirmed treatment is listed below. All 47 flagged citations have been read.
More on how this was screened

Other citing courts continued to apply Remmer's hearing requirement or its presumption.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

47 later cases cite Remmer v. United States; 47 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Remmer v. United States?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Sixth Circuit confined Remmer's presumption when evaluating the alleged outside contact with jurors and required the defendants to prove actual bias.

    United States v. Baskerville · Sixth Circuit · filed

    He asserts that any external contact with jurors should instead trigger a so-called Remmer presumption, under which juror bias is presumed and must be rebutted by the Government. ... We thus decline the invitation to presume that the alleged jury interference was prejudicial and instead apply our precedents’ prevailing actual-bias approach.
    Read the full opinion on CourtListener →

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