Brown v. Mitchell’s Empirical Analysis

Citation profile

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

1. “Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress ....”

   3 later decisions quote this exact passage · from the majority
   e.g. Wiggins v. Quesenberry · 88 F. Supp. 3d 551 - Woodson v. City of Richmond

2. “• Count I relies on 42 U.S.C. § 1983 , charging that Mitchell and the City, pursuant to an official policy or custom, maintained a crowded, poorly ventilated, and unsanitary jail, which reflected a deliberate indifference to Stevenson’s rights, as secured by the Eighth Amendment to the United States Constitution, to be free from cruel and unusual punishment and that this policy or custom caused, or contributed to cause, Stevenson’s death. • Count II also relies on Section 1983, charging that Mitchell failed to train her staff to respond adequately to inmates’ medical problems, thereby demonstrating a deliberate indifference to Stevenson’s Eighth Amendment right to be free from cruel and unusual punishment, and that this failure to train caused, or contributed to cause, Stevenson’s death. • Count III proceeds under Section 1983, charging that John Does 1-10, unidentified guards employed by the Jail, were deliberately indifferent to Stevenson’s serious medical condition and thereby violated his rights under the Eighth Amendment. • Count IV relies on Section 1983, charging that Dr. Freund was deliberately indifferent to Stevenson’s serious medical needs in violation of Stevenson’s Eighth Amendment rights and that, through his indifference, Dr. Freund caused, or contributed to cause, Stevenson’s death. • Count V alleges a state law wrongful death action against Mitchell, claiming that the grossly negligent policies and practices of the Sheriff were a cause of Stevenson’s death. V”

   1 later decision quote this exact passage · from the majority
   e.g. 327 F. Supp. 2d 615 - Brown v. Mitchell

3. “To impose liability on a supervisor for the failure to train subordinates, a plaintiff must plead and prove that: (1) the subordinates actually violated the plaintiffs constitutional or statutory rights; (2) the supervisor failed to train properly the subordinates thus illustrating a ‘deliberate indifference’ to the rights of the persons with whom the subordinates come into contact; and (3) this failure to train actually caused the subordinates to violate the plaintiffs rights.”

   1 later decision quote this exact passage · from the majority
   e.g. 187 F. Supp. 3d 648 - Jones v. Western Tidwater Regional Jail