Benson v. General Services Administration’s Empirical Analysis

Citation profile

34 federal appellate · 5 district · 3 state decisions

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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “(2) related solely to the internal personnel rules and practices of an agency.”

   5 later decisions quote this exact passage
   e.g. Hawkes v. Internal Revenue Service · 471 F. Supp. 436 - Tabcor Sales Clearing, Inc. v. Department of the Treasury

2. ““Matters related solely to the internal personnel rules and practices of any agency: Operating rules, guidelines, and manuals of procedure for Government investigators or examiners would be exempt from disclosure, but this exemption would not cover all ‘matters of internal management’ such as employee relations and working conditions and routine administrative procedures which are withheld under the present law.” H.R. Rep. No. 1497, at 10. (Emphasis added.)”

   3 later decisions quote this exact passage
   e.g. Hawkes v. Internal Revenue Service · 301 F. Supp. 796 - Consumers Union of United States, Inc. v. Veterans Administration

3. “"[T]he exemption is meant to protect information that a private individual wishes to keep confidential for his own purposes. *** The appraisal report, on the other hand, is kept confidential by the appraiser on the client’s behalf, not on his own behalf, and the client here is GSA. Thus the exemption does not apply to the appraisal report.” (Benson, 289 F. Supp. at 594 .)”

   2 later decisions quote this exact passage
   e.g. 266 Ill. App. 3d 1007 - Cooper v. Department of Lottery · 444 F. Supp. 945 - Martin Marietta Aluminum, Inc. v. Administrator, General Services Administration