T-Z’s Empirical Analysis
2007
Citation profile
28 federal appellate ·
How this case has been cited
Cited by 175 later decisions — most recently April 2025 · most notably Jian Hui Shao v. Mukasey (2008), Manzur v. U.S. Department of Homeland Security (2007)
28 federal appellate ·
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 8 U.S.C. § 1101 (§ 101 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1182E · 8 U.S.C. § 1253 (§ 243 of the Immigration and Nationality Act of 1952 (McCarran-Walter))
Relies on Immigration & Naturalization Service v. Cardoza-Fonseca · Zehatye v. Gonzales · Saideh Fisher v. Immigration and Naturalization Service · Nagoulko v. Immigration & Naturalization Service · Yu Zhao v. Gonzales
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 175 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Tjhere may be situations in which, for example, an extraordinarily severe fíne or wholesale seizure of assets may be so severe as to amount to persecution, even though the basic necessities of life might still be attainable.... This form of persecution is covered by the “economic disadvantage” test in Kovac ... [An alien] need not demonstrate a total deprivation of livelihood or a total withdrawal of all economic opportunity in order to demonstrate harm amounting to persecution [under] Kovac ... Government sanctions that reduce an applicant to an impoverished existence may amount to persecution even if the victim retains the ability to afford the bare essentials of life. A particularly onerous fine, a large-scale confiscation of property, or a sweeping limitation of opportunities to continue to work in an established profession or business may amount to persecution even though the applicant could otherwise survive.”
1 later decision quote this exact passage · from the majority“a reasonable person would objectively view the threats for refusing the abortion to be genuine, and the threatened harm, if carried out, would rise to the level of persecution.”
1 later decision quote this exact passage“the deliberate imposition of severe economic disadvantage or the deprivation of liberty, food, housing, employment or other essentials of life.”
1 later decision 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.