Wayne v. Jarvis’s Empirical Analysis
197 F.3d 1098 · 1999
Citation profile
16 federal appellate · 7 district · 4 state decisions
How this case has been cited
Cited by 86 later decisions — most recently March 2025 · most notably McDowell v. Brown (2004), Goodman v. Praxair, Inc. (2007)
16 federal appellate · 7 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
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Board of the County Commissioners of Bryan County v. Brown · Marks v. United States · Hopkins v. Reeves · Church v. City of Huntsville · Powell v. Lennon
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 86 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"`[A] plaintiff seeking to impose liability on a municipality under § 1983 [must] identify a municipal "policy" or "custom" that caused the plaintiff's injury.' Board of County Comm'rs v. Brown , 520 U.S. 397 , 403 , 117 S.Ct. 1382 , 1388 , 137 L.Ed.2d 626 (1997). `A policy is a decision that is officially adopted by the municipality, or created by an official of such rank that he or she *Page 1198 could be said to be acting on behalf of the municipality. . . . A custom is a practice that is so settled and permanent that it takes on the force of law.' Sewell v. Town of Lake Hamilton , 117 F.3d 488 , 489 (11th Cir. 1997), cert. denied, 522 U.S. 1075 , 118 S.Ct. 852 , 139 L.Ed.2d 753 (1998). We have emphasized that: "`[t]o establish a policy or custom, it is generally necessary to show a persistent and wide-spread practice. Moreover, actual or constructive knowledge of such customs must be attributed to the governing body of the municipality.' Depew v. City of St. Mary's , 787 F.2d 1496 , 1499 (11th Cir. 1986); see also Church v. City of Huntsville , 30 F.3d 1332 , 1345 (11th Cir. 1994)."”
2 later decisions quote this exact passage · from the majority“[t]he district court noted that 'under Georgia law, the DeKalb County Sheriff’s Department is not a legal entity that can be sued apart from the County.' ” Id. But we concluded that”
2 later decisions quote this exact passage · from the majority“[a]lthough [plaintiff] Wayne did not sue Dekalb County itself, his claim against Sheriff Jarvis in his official capacity is a claim against Dekalb County”
2 later decisions 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.