Seekamp v. Michaud’s Empirical Analysis
109 F.3d 802 · 1997
Citation profile
5 federal appellate · 26 district · 1 state decisions
How this case has been cited
Cited by 35 later decisions — most recently June 2022 · most notably Aponte Matos v. Toledo Dávila (1998), Martinez-Vélez v. Rey-Hernández (2007)
5 federal appellate · 26 district · 1 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
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Graham v. Connor · United States v. Sokolow · Tennessee v. Garner · United States v. Sharpe · Brower v. County of Inyo
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] supervisor: can be held liable ... if (1) the behavior of [his] subordinates results in a constitutional violation, and (2) the [supervisor]’s action or inaction was ‘affirmativeRy] link[ed]’ to that behavior in that it could be characterized as ‘supervisory encouragement, condonation or acquiescence’ or ‘gross negligence amounting to deliberate indifference.’ Moreover, the indifference required to support supervisory liability under section 1983 must be “deliberate, reckless or callous.” Thus, the ‘affirmative link’ required between the action or inaction of a supervisor and the behavior of subordinates ‘contemplates proof that the supervisor’s conduct led inexorably to the constitutional violation.’”
1 later decision quote this exact passage · from the majority“there is subordinate liability, and . . . the supervisor's action or inaction was affirmatively linked to the constitutional violation caused by the subordinate.”
1 later decision quote this exact passage · from the majority“supervisory encouragement, condonation or acquiescence, or gross negligence amounting to deliberate indifference.”
1 later decision 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.