Palmer v. Brown’s Empirical Analysis
1988
Citation profile
22 federal appellate · 85 district · 158 state decisions
How this case has been cited
Cited by 285 later decisions — most recently May 2025 · most notably Flesner v. Technical Communications Corp. (1991), Coman v. Thomas Manufacturing Co. (1989)
22 federal appellate · 85 district · 158 state decisions — followed in 13 states
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. § 1320A (§ 1128 of the Social Security Act of 1935) · 42 U.S.C. § 1320A (§ 1128a of the Social Security Act of 1935) · 42 U.S.C. § 1392 (§ 1702 of the Social Security Act of 1935) · 42 U.S.C. § 1396A (§ 1902 of the Social Security Act of 1935) · 42 U.S.C. § 1396H (§ 1909 of the Social Security Act of 1935)
Relies on Boston Firefighters Union, Local 718 v. Boston Chapter, NAACP · 85 Ill. 2d 124 - Palmateer v. International Harvester Co. · In re Quarles · Morriss v. Coleman Co. · 6 Kan. App. 2d 488 - Murphy v. City of Topeka
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 285 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Public policy requires that citizens in a democracy be protected from reprisals for performing their civil duty of reporting infractions of rules, regulations, or the law pertaining to public health, safety, and the general welfare. Thus, we have no hesitation in holding termination of an employee in retaliation for the good faith reporting of a serious infraction of such rules, regulations, or the law by a co-worker or an employer to either company management or law enforcement officials (whistle-blowing) is an actionable tort.”
26 later decisions quote this exact passage · from the majority““Before courts are justified in declaring the existence of public policy, however, ‘it should be so thoroughly established as a state of public mind so united and so definite and fixed that its existence is not subject to any substantial doubt.’ ” (Quoting Noel v. Menninger Foundation, 175 Kan. 751 , Syl. ¶ 4, 267 P.2d 934 [1954].)”
3 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.