Pennhurst State School and Hospital v. Halderman’s Empirical Analysis
1981
Citation profile
1,245 federal appellate · 459 district · 188 state decisions
How this case has been cited
Cited by 3,571 later decisions (145 by the Supreme Court) — most recently June 2026 · most notably Pennhurst State School and Hospital v. Halderman (1984), Will v. Michigan Department of State Police (1989)
1,245 federal appellate · 459 district · 188 state decisions — followed in 29 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
reviewedHalderman v. Pennhurst State School & Hospital (from Third Circuit Court of Appeals)
Relationships
Applies 29 U.S.C. § 701 (Employment Opportunities for Individuals With Disabilities Act) · 29 U.S.C. § 794 · 42 U.S.C. § 1396D (§ 1905 of the Social Security Act of 1935) · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 2689 · 42 U.S.C. § 6000 (Developmental Disabilities Act of 1984)
Relies on Adickes v. S. H. Kress & Co. · Edelman v. Jordan · Cort v. Ash · Preiser v. Rodriguez · San Antonio Independent School District v. Rodriguez
Cited together with Maine v. Thiboutot · Middlesex County Sewerage Authority v. National Sea Clammers Assn. · Wright v. City of Roanoke Redevelopment & Housing Authority · Cannon v. University of Chicago · Cort v. Ash
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 3,571 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“By insisting that Congress speak with a clear voice, we enable the States to exercise their choice knowingly, cognizant of the consequences of their participation.”
192 later decisions quote this exact passage“‘governing statute provides an exclusive remedy for violations of its terms.’ ” Irby, 737 F.2d at 1428 , citing Halderman, 451 U.S. at 28 , 101 S.Ct. at 1545 (citation omitted).”
24 later decisions quote this exact passage · from the majority“In legislation enacted pursuant to the spending power, the typical remedy for state noncompliance with federally imposed conditions is not a private cause of action for noncompliance but rather action by the Federal Government to terminate funds to the State.”
18 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.