414 Theater Corp. v. Murphy’s Empirical Analysis
499 F.2d 1155 · 1974
Citation profile
22 federal appellate · 7 district · 3 state decisions
How this case has been cited
Cited by 56 later decisions — most recently June 2025 · most notably Triebwasser & Katz, a Partnership Consisting of Jonah Triebwasser and William Katz v. American Telephone & Telegraph Company (1976), John B. Hull, Inc. v. Waterbury Petroleum Products, Inc. (1978)
22 federal appellate · 7 district · 3 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 Younger v. Harris · Monroe v. Pape · Roe v. Wade · Steffel v. Thompson · Dombrowski v. Pfister
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“. (T)he other option — violating the law to exercise one’s constitutional rights and awaiting the sure hand of the law — itself may cause, as it is alleged to cause, irreparable injury both economic (in the form of loss of revenue because customers are fewer and increase in costs due to the difficulty of finding employees willing to risk arrest, prosecution and possible imprisonment) and personal (the freedom to exercise first amendment rights without genuine fear of prosecution). Where other plaintiffs have faced the similar situation of being required to forego constitutionally protected activity in order to avoid arrest, the Supreme Court has found irreparable injury (citations omitted).”
2 later decisions quote this exact passage · from the majority““The latter possibility . . . involves a deprivation of [plaintiff’s] and the public’s first amendment rights to show and to view films, and in itself constitutes irreparable injury justifying injunctive relief, because there is no means to make up for the irretrievable loss of that which would have been expressed. Moreover, the other option — violating the law to exercise one’s constitutional rights and awaiting the sure hand of the law— itself may cause, as it is alleged to cause, irreparable injury both economic . and personal . . ..””
1 later decision quote this exact passage · from the majority“Where the state court has deliberately avoided an interpretation of a statute which might save its constitutionality or moot the federal claim, the abstaining federal court may certainly reassert the jurisdiction it was retaining in order to reach the merits. Neither comity nor sound judicial administration require the abstaining federal court to wait indefinitely for state courts to determine the merits.”
1 later decision quote this exact passage · from the majoritye.g. Pugh v. Rainwater
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.