Case Citator › Yates v. United States

Yates v. United States

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

Overruled in part
Court
Supreme Court of the United States
Citation
354 U.S. 298
Decided
Confirmed treatments
1
Flagged citations read
204 of 204
Citing cases (total)
1,277
Treatment dates
1978
Overruled in part
A reviewed court has overruled part of this case’s holding. Yates v. United States has been overruled in part: all 204 flagged citations have been read, with the 1 confirmed treatment listed below. Burks v. United States displaced Yates's appellate-remedy holding that a defendant who requested a new trial could be retried after an appellate court found the trial evidence insufficient.
More on how this was screened

The reviewed citing opinions overwhelmingly copied history parentheticals reporting Burks's act; those recognizers are not the treating courts. Other citing opinions applied Yates's advocacy, conspiracy, limitations, intent, or evidentiary rules, or directed nearby treatment language at unrelated authorities. Burks did not overrule those other holdings.

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.

1,277 later cases cite Yates v. United States; 204 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 Yates 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

Overruled in part

  • The Court overruled Yates's rule permitting a new trial after reversal for evidentiary insufficiency when the defendant had requested that remedy.

    Burks v. United States · Supreme Court of the United States · filed

    The Yates decision thus paralleled Sapir’s concurrence in the sense that both would allow a new trial to correct evidentiary insufficiency if the defendant had requested such relief — even as an alternative to a motion for acquittal. ... Since we hold today that the Double Jeopardy Clause precludes a second trial once the reviewing court has found the evidence legally insufficient, the only “just” remedy available for that court is the direction of a judgment of acquittal. To the extent that our prior decisions suggest that by moving for a new trial, a defendant waives his right to a judgment of acquittal on the basis of evidentiary insufficiency, those cases are overruled.
    Read the full opinion on CourtListener →

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