Hunter v. Underwood’s Empirical Analysis
1985
Citation profile
231 federal appellate · 37 district · 113 state decisions
How this case has been cited
Cited by 752 later decisions (29 by the Supreme Court) — most recently December 2025 · most notably City of Cleburne Texas v. Cleburne Living Center (1985), Price Waterhouse v. Hopkins (1989)
231 federal appellate · 37 district · 113 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
reviewedUnderwood v. Hunter (from Eleventh Circuit Court of Appeals)
Relationships
Relies on Mt. Healthy City School District Board of Education v. Doyle · Village of Arlington Heights v. Metropolitan Housing Development Corp. · United States v. O'Brien · Washington v. Davis · Pullman-Standard v. Swint
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 752 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Once racial discrimination is shown to have been a 'substantial' or 'motivating' factor behind enactment of the law, the burden shifts to the law's defenders to demonstrate that the law would have been enacted without this factor.”
39 later decisions quote this exact passage · from the majority“any ... crime involving moral turpitude.”
8 later decisions quote this exact passage“[Section] 2 was not designed to permit the purposeful racial discrimination [in Alabama's criminal disenfranchisement law] ... which otherwise violates [Section] 1 of the Fourteenth Amendment. Nothing in ... Richardson v. Ramirez suggests the contrary.”
5 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.