Aldinger v. Howard’s Empirical Analysis
1976
Citation profile
581 federal appellate · 445 district · 64 state decisions
How this case has been cited
Cited by 2,440 later decisions (21 by the Supreme Court) — most recently April 2025 · most notably Monell v. Department of Social Services of City of New York (1978), Pennhurst State School and Hospital v. Halderman (1984)
581 federal appellate · 445 district · 64 state decisions — followed in 17 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
reviewedAldinger v. Howard (from Ninth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 1331 · 28 U.S.C. § 1332 (Class Action Fairness Act of 2005) · 28 U.S.C. § 1343 · 28 U.S.C. § 1346 (Federal Tort Claims Act) · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 1986
Relies on United Mine Workers of America v. Gibbs · Monroe v. Pape · Zwickler v. Koota · Moor v. County of Alameda
Cited together with United Mine Workers of America v. Gibbs · Owen Equipment & Erection Co. v. Kroger · Monell v. Department of Social Services of City of New York · Moor v. County of Alameda · 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 2,440 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Congress in [that statute] has ... expressly or by implication negated”
123 later decisions quote this exact passage · from the majority““From a purely factual point of view, it is one thing to authorize two parties, already present in federal court by virtue of a case over which the court has jurisdiction, to litigate in addition to their federal claim a state-law claim over which there is no independent basis of federal jurisdiction. But it is quite another thing to permit a plaintiff, who has asserted a claim against one defendant with respect to which there is federal jurisdiction, to join an entirely different defendant on the basis of a state-law claim over which there is no independent basis of federal jurisdiction, simply because his claim against the first defendant and his claim against the second defendant ‘derive from a common nucleus of operative fact.’ ... [T]he addition of a completely new party would run counter to the well-established principle that federal courts, as opposed to state trial courts of general jurisdiction, are courts of limited jurisdiction marked out by Congress.” Aldinger, 96 S.Ct. at 2420 (quoting Gibbs, 86 S.Ct. at 1138 ).”
44 later decisions quote this exact passage · from the majority“). 32 [I]f, considered without regard to their federal or state character, a plaintiff's claims are such that he would ordinarily be expected to try them all in one judicial proceeding, then, assuming substantiality of the federal issues, there is power in federal courts to hear the whole. 33 United Mine Workers v. Gibbs, 383 U.S. at 725, 86 S.Ct. at 1138 (emphasis in original). The claims against the individuals here are so closely related to both federal and state claims against the Local that we are willing to assume, constitutionally speaking, that”
24 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.