Donovan v. Lone Steer, Inc.’s Empirical Analysis
1984
Citation profile
49 federal appellate · 18 district · 59 state decisions
How this case has been cited
Cited by 180 later decisions (10 by the Supreme Court) — most recently November 2025 · most notably McConnell United States Senator et al. v. Federal Election Commission et al. (2003), 199 W. Va. 12 - State Ex Rel. Hoover v. Berger (1997)
49 federal appellate · 18 district · 59 state decisions — followed in 13 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.
Relationships
Applies 15 U.S.C. § 49 (§ 9 of the Federal Trade Commission Act of 1914) · 29 U.S.C. § 201 (American Samoa Labor Standards Amendments of 1956) · 29 U.S.C. § 209 · 29 U.S.C. § 211
Relies on Camara v. Municipal Court of City and County of San Francisco · See v. City of Seattle · Marshall v. Barlow's, Inc. · United States v. Morton Salt Co. · Local 408, International Brotherhood of Teamsters v. National Labor Relations Board
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 180 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“question the reasonableness of the subpoena, before suffering any penalties for refusing to comply with it, by raising objections in an action in district court.”
9 later decisions quote this exact passage · from the majority“'sufficiently limited in scope, relevant in purpose, and specific in directive so that compliance will not be unreasonably burdensome.'”
5 later decisions quote this exact passage · from the majority“invoke the aid of any court of the United States in requiring ... production of documentary evidence.”
2 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.