130 F. Supp. 2d 23 - Steele v. Isikoff’s Empirical Analysis
2000
Citation profile
16 district · 2 state decisions
How this case has been cited
Cited by 25 later decisions — most recently April 2022 · most notably 251 F. Supp. 2d 77 - In Re US Office Products Co. Securities Lit. (2003), 543 F. Supp. 2d 1 - Paul v. Judicial Watch, Inc. (2008)
16 district · 2 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 Papasan v. Allain · Hustler Magazine, Inc. v. Falwell · Kowal v. MCI Communications Corp. · Innkeepers of New Castle, Inc. v. Maley · Equal Employment Opportunity Commission v. St. Francis Xavier Parochial School
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As in Minnesota, moral obligations do not give rise to contractual liability under the laws of the District of Columbia or Virginia. See, e.g., Baker v. District of Columbia, 39 App. D.C. 42, 44-45 (App.D.C.1912) (“It is elementary in the law of contracts that a promise of a person competent, made under a sense of moral obligation ... is not legally binding.”); Mihalcoe v. Holub, 130 Va. 425 , 107 S.E. 704, 706 (1921) (“[A] mere moral obligation is not a sufficient foundation for an implied contract-”). Accordingly, because a reporter’s promise of confidentiality is a moral obligation, not a contractual requirement, and because a moral obligation does not give rise to express or implied contractual duties, there is no contractual relationship between [the reporter and source]. Without contracts on which to base them, [the source’s] breach of contract claims will be dismissed.”
2 later decisions quote this exact passage · from the majority“We are not persuaded that in the special milieu of media newsgathering a source and a reporter ordinarily believe they are engaged in making a legally binding contract. They are not thinking in terms of offers and acceptances in any commercial or business sense. The parties understand that the reporter’s promise of anonymity is given as a moral commitment, but a moral obligation alone will not support a contract. Indeed, a payment of money, which taints the integrity of the newsgathering function, such as money paid a reporter for the publishing of a news story, is forbidden by the ethics of journalism. In other words, contract law seems here an ill fit for a promise of news source confidentiality. To impose a contract theory on this arrangement puts an unwarranted legal rigidity on a special ethical relationship, precluding necessary consideration of factors underlying that ethical relationship. We conclude that a contract cause of action is inappropriate for these particular circumstances.”
1 later decision quote this exact passage · from the majority“If a party seeks damages for non-reputational harms, which include lost jobs and diminished employment prospects, then the First Amendment does not bar suit as long as the claims are brought under generally applicable laws.”
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.