Sweeney v. Patterson’s Empirical Analysis
128 F.2d 457 · 1942
Citation profile
24 federal appellate · 4 district · 21 state decisions
How this case has been cited
Cited by 62 later decisions (6 by the Supreme Court) — most recently September 2024 · most notably New York Times Co. v. Sullivan (1964), Curtis Publishing Co. v. Butts (1967)
24 federal appellate · 4 district · 21 state decisions — followed in 13 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
Relies on Coleman v. MacLennan · Washington Times Co. v. Bonner · Snively v. Record Publishing Co. · Schenectady Union Publishing Co. v. Sweeney · Sillars v. Collier
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 62 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Errors of fact, particularly in regard to a man’s mental states and processes, are inevitable. Information and discussion will be discouraged, and the public interest in public knowledge of important facts will be poorly defended, if error subjects its author to a libel suit without even a showing of economic loss. Whatever is added to the field of libel is taken from the field of free debate.” 76 U.S.App.D.C. at 24 , 128 F.2d at 458 .”
3 later decisions quote this exact passage““Cases which impose liability for erroneous reports of the political conduct of officials reflect the obsolete doctrine that the governed must not criticize their governors. . . . The interest of the public here outweighs the interest of appellant or any other individual. The protection of the public requires not merely discussion, but information.””
3 later decisions quote this exact passage“Even if the [appellees'] statements are false, appellant has stated no claim on which relief can be granted. The cases are in conflict, but in our view it is not actionable to publish erroneous and injurious statements of fact and injurious comment or opinion regarding the political conduct and views of public officials, so long as no charge of crime, corruption, gross immorality or gross incompetence is made and no special damage results. Such a publication is not `libelous per se.' We need not consider whether it is privileged. Appellant might be entitled to relief if he had lost his seat in Congress, or had lost employment, as a lawyer or otherwise, or had been put to expense, or had suffered any other economic injury, by reason of appellees' statements. We do not decide that question, since it is not before us. Appellant alleges no such injury.”
1 later decision quote this exact passage
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.