Zschernig v. Miller’s Empirical Analysis
1968
Citation profile
130 federal appellate · 53 district · 114 state decisions
How this case has been cited
Cited by 487 later decisions (43 by the Supreme Court) — most recently April 2026 · most notably Hillsborough County v. Automated Medical Laboratories, Inc. (1985), Verlinden B. v. v. Central Bank of Nigeria (1983)
130 federal appellate · 53 district · 114 state decisions — followed in 21 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
Relies on Ashwander v. Tennessee Valley Authority · Hines v. Davidowitz · Poe v. Ullman · International Ass'n of MacHinists v. Street · Giles v. State of Maryland
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 487 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“great potential for disruption or embarrassment”
8 later decisions quote this exact passage · from the majority“an intrusion by the State into the field of foreign affairs which the Constitution entrusts to the President and the Congress,”
7 later decisions quote this exact passage · from the majority“inquiries into the type of governments that obtain in particular foreign nations' — whether aliens under their law have enforceable rights, whether the so-called “rights” are merely dispensations turning upon the whim or caprice of government officials, whether the representation of consuls, ambassadors, and other representatives of foreign nations is credible or made in good faith, whether there is in the actual administration in the particular foreign system of law any element of confiscation.”
6 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.