J-E’s Empirical Analysis
2002
Citation profile
37 federal appellate · 4 district ·
How this case has been cited
Cited by 84 later decisions — most recently April 2024 · most notably Sevoian v. Ashcroft (2002), Zubeda v. Ashcroft (2003)
37 federal appellate · 4 district ·
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 28 U.S.C. § 1350 (Torture Victim Protection Act of 1991) · 8 U.S.C. § 1231 (§ 241 of the Immigration and Nationality Act of 1952 (McCarran-Walter))
Relies on Estelle v. Gamble · In the Matter of Samuel Winship · Immigration & Naturalization Service v. Elias-Zacarias · Immigration & Naturalization Service v. Cardoza-Fonseca · Wilson v. Seiter
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 84 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]lthough Haitian authorities are intentionally detaining criminal deportees knowing that the detention facilities are substandard, there is no evidence that they are intentionally and deliberately creating and maintaining such prison conditions in order to inflict torture.”
3 later decisions quote this exact passage“[i]nstances of police brutality do not necessarily rise to the level of torture, whereas deliberate vicious acts such as burning with cigarettes, choking, hooding, kalot marassa, and electric shock may constitute acts of torture.”
2 later decisions quote this exact passage“does not mean that proof of specific intent, as that term is used in American criminal prosecutions, is required.... The majority's reading of the regulations functionally converts the Senate understanding that torture must be”
2 later decisions quote this exact passage · from the concurrence
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.