Armstrong’s Empirical Analysis
Citation profile
24 federal appellate · 40 district · 3 state decisions
How this case has been cited
Cited by 100 later decisions — most recently January 2025 · most notably Shepherd v. American Broadcasting Companies (1995), Broderick v. Donaldson (2006)
24 federal appellate · 40 district · 3 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
Relies on Steffel v. Thompson · Shillitani v. United States · Perez v. Ledesma · Kissinger v. Reporters Committee for Freedom of the Press · International Longshoremen's Ass'n, Local 1291 v. Philadelphia Marine Trade Ass'n
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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Djocumentary materials ... created or received by the President, his immediate staff, or a unit or individual of the Executive Office of the President whose function is to advise and assist the President, in the course of conducting activities which relate to or have an effect upon the carrying out of the constitutional, statutory, or other official or ceremonial duties of the President.”
5 later decisions quote this exact passage · from the concurrence“[a] "creation" decision refers to the determination to make a record documenting presidential activities. Thus, the courts may not review any decisions regarding whether to create a documentary presidential record. "Management decisions" describes the day-to-day process by which presidential records are maintained. The courts may likewise not review these particulars of the presidential records management system. Finally, "disposal decisions" describes the process outlined in [the PRA] for disposing of presidential records. Judicial review of the President's action under these provisions is also unavailable. But guidelines describing which existing materials will be treated as presidential records in the first place are subject to judicial review.”
4 later decisions quote this exact passage · from the concurrence“Armstrong II held that guidelines for categorizing Presidential records are subject to judicial review ‘to ensure that materials that are not subject to the PRA are not treated as Presidential records.’ Accordingly, in turn, the Court observes that Armstrong II does not necessarily foreclose judicial review of a decision to denominate certain materials ‘personal records’ of a former President. Such judicial review may be available to ensure that Presidential records are not disposed of as personal records at the end of an Administration and that, instead, all Presidential records fall subject to the Archivist’s ‘affirmative duty to make such records available to the public.’”
3 later decisions quote this exact passage · from the concurrence
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.