Poland v. Chertoff’s Empirical Analysis
494 F.3d 1174 · 2007
Citation profile
17 federal appellate · 25 district · 9 state decisions
How this case has been cited
Cited by 100 later decisions (1 by the Supreme Court) — most recently February 2025 · most notably Ricci v. DeStefano (2009), Cafasso v. General Dynamics C4 Systems, Inc. (2011)
17 federal appellate · 25 district · 9 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
Applies 28 U.S.C. § 2412 · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964) · 42 U.S.C. § 2000E (§ 704 of the Title VII of the Civil Rights Act of 1964)
Relies on McDonnell Douglas Corp. v. Green · Buckhannon Board and Care Home Incs v. West Virginia Department of Health and Human Resources · Jett v. Dallas Independent School District · Hewitt v. Helms · Pennsylvania State Police v. Suders
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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]f a subordinate, in response to a plaintiffs protected activity, sets in motion a proceeding by an independent decision-maker that leads to an adverse employment action, the subordinate’s bias is imputed to the employer if the plaintiff can prove that the allegedly independent adverse employment decision was not actually independent because the biased subordinate influenced or was involved in the decision or decisionmaking process.”
8 later decisions quote this exact passage · from the majority“[C]onstructive discharge occurs when the working conditions deteriorate, as a result of discrimination, to the point that they become sufficiently extraordinary and egregious to overcome the normal motivation of a competent, diligent, and reasonable employee to remain on the job to earn a livelihood and to serve his or her employer. We set the bar high for a claim of constructive discharge because federal antidiscrimination policies are better served when the employee and employer attack discrimination within their existing employment relationship, rather than when the employee walks away and then later litigates whether his employment situation was intolerable.”
3 later decisions quote this exact passage · from the dissent“influenced or was involved in the adverse employment decision.”
3 later decisions quote this exact passage · from the dissent
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.