Houston v. Lack’s Empirical Analysis
1988
Citation profile
1,071 federal appellate · 177 district · 535 state decisions
How this case has been cited
Cited by 6,324 later decisions (25 by the Supreme Court) — most recently August 2025 · most notably Bowles v. Russell (2007), Torres v. Oakland Scavenger Co. (1988)
1,071 federal appellate · 177 district · 535 state decisions — followed in 41 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
reviewedClarence Halcomb v. Otis R. Bowen, Secretary, Department of Health and Human Services, Defendant (from Sixth Circuit Court of Appeals)
Relationships
Relies on Browder v. Director Department of Corrections of Illinois · Griggs v. Provident Consumer Discount Co. · United States v. Boyle · United States v. Locke
Cited together with Bowles v. Russell · Browder v. Director Department of Corrections of Illinois · Haines v. Kerner · Fallen v. United States · Thompson v. Immigration and Naturalization Service
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 6,324 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The situation of prisoners seeking to appeal without the aid of counsel is unique. Such prisoners cannot take the steps other litigants can take to monitor the processing of their notices of appeal and to ensure that the court clerk receives and stamps their notices of appeal before the 30-day deadline. Unlike other litigants, pro se prisoners cannot personally travel to the courthouse to see that the notice is stamped “filed” or to establish the date on which the court received the notice. Other litigants may choose to entrust their appeals to the vagaries of the mail and the clerk’s process for stamping incoming papers, but only the pro se prisoner is forced to do so by his situation. And if other litigants do choose to use the mail, they can at least place the notice directly into the hands of the United States Postal Service (or a private carrier); and they can follow its progress by calling the court to determine whether the notice has been received and stamped, knowing that if the mail goes awry they can personally deliver notice at the last moment or that their monitoring will provide them with evidence to demonstrate either excusable neglect or that the notice was not stamped on the date the court received it.”
103 later decisions quote this exact passage · from the majority“the moment at which pro se prisoners necessarily lose control over and contact with their notices of appeal is at delivery to prison authorities, not receipt by the clerk.”
29 later decisions quote this exact passage · from the concurrence“the Court of Appeals had jurisdiction over petitioner's appeal because the notice of appeal was filed at the time petitioner delivered it to the prison authorities for forwarding to the court clerk.”
17 later decisions quote this exact passage · from the concurrencee.g. Moore v. Neal · Nigro v. Sullivan
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.