Hafer v. Melo’s Empirical Analysis
1991
Citation profile
703 federal appellate · 720 district · 416 state decisions
How this case has been cited
Cited by 3,944 later decisions (17 by the Supreme Court) — most recently June 2026 · most notably Arizonans for Official English v. Arizona (1997), Vermont Agency of Natural Resources v. United States Ex Rel. Stevens (2000)
703 federal appellate · 720 district · 416 state decisions — followed in 39 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
reviewedMelo v. Hafer (from Third Circuit Court of Appeals)
Relationships
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Monell v. Department of Social Services of City of New York · Harlow v. Fitzgerald · Scheuer v. Rhodes · Ex Parte: Edward T Young · Edelman v. Jordan
Cited together with Will v. Michigan Department of State Police · Kentucky v. Graham · Monell v. Department of Social Services of City of New York · Harlow v. Fitzgerald · Anderson v. Liberty Lobby, Inc.
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 3,944 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“generally represent only another way of pleading an action against an entity of which an officer is an agent.”
124 later decisions quote this exact passage“[O]fficials seeking absolute immunity must show that such immunity is justified for the governmental function at issue.”
17 later decisions quote this exact passage · from the majority“state officials, sued in their individual capacities, are 'persons' within the meaning of § 1983. The Eleventh Amendment does not bar such suits, nor are state officers absolutely immune from personal liability under § 1983 solely by virtue of the 'official' nature of their acts.”
11 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.