Gertz v. Robert Welch, Inc.’s Empirical Analysis
1974
Citation profile
1,528 federal appellate · 815 district · 4,022 state decisions
How this case has been cited
Cited by 8,418 later decisions (223 by the Supreme Court) — most recently February 2026 · most notably Anderson v. Liberty Lobby, Inc. (1986), Connick v. Myers (1983)
1,528 federal appellate · 815 district · 4,022 state decisions — followed in 50 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.
Appellate journey
reviewedGertz v. Robert Welch, Inc. (from Seventh Circuit Court of Appeals)
Relationships
Relies on In the Matter of Samuel Winship · Younger v. Harris · New York Times Co. v. Sullivan · Mapp v. Ohio
Cited together with New York Times Co. v. Sullivan · St. Amant v. Thompson · Curtis Publishing Co. v. Butts · Garrison v. State of Louisiana · Bose Corp. v. Consumers Union of United States, Inc.
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 8,418 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Under the First Amendment there is no such thing as a false idea. However pernicious an opinion may seem, we depend for its correction not on the conscience of judges and juries but on the competition of other ideas. But there is no constitutional value in false statements of fact.”
771 later decisions quote this exact passage · from the concurrence“subjective awareness of probable falsity.”
49 later decisions quote this exact passage · from the dissent“There is, first, a strong interest in debate on public issues, and, second, a strong interest in debate about those persons who are in a position significantly to influence the resolution of those issues. Criticism of government is at the very center of the constitutionally protected area of free discussion. Criticism of those responsible for government operations must be free, lest criticism of government itself be penalized. It is clear, therefore, that the “public official” designation applies at the very least to those among the hierarchy of government employees who have, or appear to the public to have, substantial responsibility for or control over the conduct of governmental affairs.”
14 later decisions quote this exact passage · from the dissent
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.