O'Neill’s Empirical Analysis
Citation profile
17 district · 2 state decisions
How this case has been cited
Cited by 51 later decisions — most recently May 2023 · most notably Maym-Melndez v. Lvarez-Ramrez, 996 F. Supp. 409 - Assisted Living Associates of Moorestown, L.L.C. v. Moorestown Township (1998)
17 district · 2 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
Relies on Monell v. Department of Social Services of City of New York · Younger v. Harris · Parratt v. Taylor · Colorado River Water Conservation District v. United States · Monroe v. Pape
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[S]tate proceedings remain "pending," within the meaning of Younger abstention, ... where a coercive administrative proceeding has been initiated by the State in a state forum, where adequate state-court judicial review of the administrative determination is available to the federal claimants, and where the claimants have chosen not to pursue their state-court judicial remedies, but have instead sought to invalidate the State's judgment by filing a federal action.”
4 later decisions quote this exact passage · from the majority“[t]he critical distinction between Dayton Christian Schools and Patsy is that Patsy involved a remedial action brought by the plaintiff to vindicate a wrong which had been inflicted by the State. In contrast, Dayton Christian Schools involved an administrative proceedings [sic] initiated by the State, before a state forum, to enforce a violation of state law. That is, in Dayton Christian Schools, the action taken by the Ohio Civil Rights Commission was coercive rather than remedial, just as the action taken by the City of Philadelphia, to enforce its traffic tickets against O’Neill and Goodman, was coercive action which the plaintiffs sought to circumvent by filing their complaint in federal court.”
3 later decisions quote this exact passage · from the dissent“(1) “the state courts may construe state law in a way which renders a constitutional decision unnecessary,” and (2) “interests of comity are advanced, and friction reduced, if the courts of a state, rather than the federal courts, determine that the United States Constitution requires the state to alter its practices.””
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.