Fowler v. Curtis Publishing Co.’s Empirical Analysis
182 F.2d 377 · 1950
Citation profile
23 federal appellate · 11 district · 4 state decisions
How this case has been cited
Cited by 59 later decisions — most recently October 2024 · most notably Browning v. Clinton (2002), Raymond Richardson, Jr. v. Hugh F. Rivers, D. C. Board of Parole (1964)
23 federal appellate · 11 district · 4 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 Erick Bowman Remedy Co. v. Jensen Salsbery Laboratories, Inc. · National Refining Co. v. Benzo Gas Motor Fuel Co. · Dooling v. Budget Publishing Co. · Dent v. Balch
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 59 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]f the plaintiff desired to predicate its right to recover damages upon general loss of custom, it should have alleged facts showing an established business, the amount of sales for a substantial period preceding the publication, the amount of sales subsequent to the publication, [and] facts showing that such loss in sales were the natural and probable result of such publication^]”
3 later decisions quote this exact passage · from the majority““4. As a result of the malicious publication of said libelous article and photographs the business of the plaintiff Thomas W. Fowler, has been subjected to an unwarranted and undesired publicity and the good will which the plaintiff has heretofore enjoyed has been destroyed and said publication has caused many of the persons who have been renting taxicabs from the plaintiff to refrain from renting ‘Columbia Cabs’ and plaintiff Thomas W. Fowler, in the operation of his business has been otherwise seriously injured, his credit has been destroyed, and his standing in the taxicab industry has been damaged and impaired; all to his damage in the sum of One Hundred Thousand ($100,000.00) Dollars. “5. As a result of the malicious publication of said libelous article and photographs as aforesaid, the plaintiff Charles D. Howery and fifty-nine other Columbia Cab drivers have been injured in their business and have been brought into public scandal disgrace and held up to public ridicule, hatred and contempt and have lost the confidence of the public; all to the damage of said plaintiffs in the sum of Three Hundred Thousand ($300,000.00) Dollars”.”
1 later decision quote this exact passage · from the majority““Even assuming that the article is defamatory of Columbia taxicab drivers as a group, rather than generally of all taxicab drivers applying their trade in the City of Washington, no individual Columbia taxicab driver has a cause of action for libel.””
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.