Drumm v. Brown’s Empirical Analysis
1998
Citation profile
89 state decisions
How this case has been cited
Cited by 89 later decisions — most recently November 2017 · most notably D'ERAMO v. Smith (2005), Garcia v. City of Hartford (2009)
89 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 25 U.S.C. § 1302 (§ 202 of the Indian Civil Rights Act of 1968) · 25 U.S.C. § 1751 (Mashantucket Pequot Indian Claims Settlement Act) · 25 U.S.C. § 1758 · 25 U.S.C. § 450 (§ 2 of the Indian Self-Determination and Education Assistance Act of 1975) · 28 U.S.C. § 1331 · 28 U.S.C. § 1332 (Class Action Fairness Act of 2005)
Relies on Younger v. Harris · Colorado River Water Conservation District v. United States · Gulf Oil Corporation v. Gilbert · Steffel v. Thompson · Morton v. Mancari
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 89 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Under our exhaustion of administrative remedies doctrine, a trial court lacks subject matter jurisdiction over an action that seeks a remedy that could be provided through an administrative proceeding, unless and until that remedy has been sought in the administrative forum. . . . In the absence of exhaustion of that remedy, the action must be dismissed.”
22 later decisions quote this exact passage“Generally, in the absence of strong countervailing consideration, [t]he plaintiff's choice of forum [notwithstanding that it] may well have been chosen . . . because it provides the plaintiff with certain procedural or substantive advantages, should be respected. . . .”
2 later decisions quote this exact passage“[The [exhaustion] doctrine is not jurisdictional; that is, it does not go to, affect, or depend directly upon, the jurisdiction of either the tribal or the nontribal court.”
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.