Doe v. State’s Empirical Analysis
1990
Citation profile
2 district · 67 state decisions
How this case has been cited
Cited by 69 later decisions — most recently November 2025 · most notably New Mexico Right to Choose/NARAL v. Johnson (1999), Moore v. Ganim (1995)
2 district · 67 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 Gault · Alyeska Pipeline Service Company v. Wilderness Society · Ohio Bureau of Employment Services v. Hodory · McGowan v. State of Maryland Gallagher · Boddie v. Connecticut
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 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a party cannot recover attorneys' fees in the absence of statutory authority or a contractual provision.”
8 later decisions quote this exact passage“[O]ur legislature has not chosen to repudiate the American rule, but rather has made specific provisions for attorneys' fees in selected cases.”
2 later decisions quote this exact passage · from the concurrence“`was never intended to guarantee the right to litigate entirely without expense to the litigants.'”
2 later decisions 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.