Sparks v. Griffin’s Empirical Analysis
460 F.2d 433 · 1972
Citation profile
45 federal appellate · 2 state decisions
How this case has been cited
Cited by 64 later decisions — most recently October 2014 · most notably 169 W. Va. 673 - Harless v. First National Bank in Fairmont (1982), 11 Fair empl.prac.cas. 872, 10 Empl. Prac. Dec. P 10,504 Sandra Lee Kaplan v. International Alliance of Theatrical and Stage Employees and Motion Picture MacHine Operators of the United States and Canada, and Local 659, International Photographers of the Motion Picture Industries (1975)
45 federal appellate · 2 state decisions
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 Monroe v. Pape · McNeese v. Board of Education for Community Unit School District 187 Cahokia · Local Union No. 12 v. National Labor Relations Board · Damico v. California · Singleton v. Jackson Municipal Separate School District
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The district court ruled that neither plaintiff-appellant had any legitimate expectancy of continued employment by the Union Hill Independent School District because neither one had tenure and it had long been the custom to reconsider the contract of every teacher in the district on an annual basis. While the expectancy of continued employment has been an important issue in several decisions of this Court dealing with public educational institutions, see, e. g. Sinderman v. Perry, 5 Cir., 1970, 430 F.2d 939 , cert. granted, 1971, 403 U.S. 917 , 91 S.Ct. 2226 , 29 L.Ed.2d 694 (alleged refusal to renew teaching contract because of teacher’s exercise of First Amendment rights), we have never recognized the relevancy of this concept to school desegregation proceedings. The plaintiffs-appellants in this case, both blacks, have charged that their contracts were not renewed for the 1968-1969 academic year for racially discriminatory reasons. The mere fact that they were not offered new contracts for the following year rather than being dismissed outright does not limit their right to seek relief under the controlling decisions of this Court.” 460 F.2d at 442 .”
1 later decision quote this exact passage · from the majority“The specific per se cast of Singleton is more procedural than substantive in its protection of the Fourteenth Amendment rights of principals and teachers affected by desegregation orders, even though the substantive thrust of Singleton is clearly an exposition of pre-Singleton law. Singleton’s novelty is procedural in the very sense of that per se pitch, for, if the facts of a case fall within the ambit of Singleton , the board is given no authority to explain its failure to reinstate. . . . But we must take cognizance of the fact that some school districts could conceivably have passed over demoted or dismissed applicants of one race in order to hire applicants of another race whom the board, in good faith and without racial discrimination, considered “more qualified” than the earlier principals or teachers. That possibility is “ . . . an operative fact and may have consequences which cannot justly be ignored. The past cannot always be erased by a new judicial declaration.” Chicot County Drainage Dist. v. Baxter State Bank, 1940, 308 U.S. 371, 374 , 60 S.Ct. 317 , 84 L.Ed. 329 . . ..”
1 later decision quote this exact passage · from the majority““If there is to be a reduction in the number of principals, teachers, teacher-aides, or other professional staff employed by the school district which will result in a dismissal or demotion of any such staff members, the staff member to be dismissed or demoted must be selected on the basis of objective and reasonable non-discriminatory standards from among all the staff of the school district. In addition if there is any such dismissal or demotion, no staff vacancy may be filled through recruitment of a person of a race, color, or national origin different from that of the individual dismissed or demoted, until each displaced staff member who is qualified has had an opportunity to fill the vacancy and has failed to accept an offer to do so.” (Emphasis added.)”
1 later decision 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.