Fitzpatrick v. Bitzer’s Empirical Analysis
1976
Citation profile
1,030 federal appellate · 530 district · 106 state decisions
How this case has been cited
Cited by 3,651 later decisions (119 by the Supreme Court) — most recently May 2025 · most notably Monell v. Department of Social Services of City of New York (1978), Hensley v. Eckerhart (1983)
1,030 federal appellate · 530 district · 106 state decisions — followed in 23 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
reviewedFitzpatrick v. Bitzer (from Second Circuit Court of Appeals)
Relationships
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964) · 42 U.S.C. § 2000E (§ 703 of the Title VII of the Civil Rights Act of 1964) · 42 U.S.C. § 2000E (§ 706 of the Title VII of the Civil Rights Act of 1964)
Relies on Ex Parte: Edward T Young · Edelman v. Jordan · Monroe v. Pape · Hans v. State of Louisiana
Cited together with Edelman v. Jordan · Hans v. State of Louisiana · Ex Parte: Edward T Young · Pennhurst State School and Hospital v. Halderman · Atascadero State Hospital v. Scanlon
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 3,651 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Legislation which deters or remedies constitutional violations can fall within the sweep of Congress' enforcement power even if in the process it prohibits conduct which is not itself unconstitutional and intrudes into `legislative spheres of autonomy previously reserved to the States.'”
147 later decisions quote this exact passage“The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.”
17 later decisions quote this exact passage · from the dissent“governments, governmental agencies, [and] political subdivisions.”
15 later decisions quote this exact passage · from the concurrence
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.