Sale v. Haitian Centers Council, Inc.’s Empirical Analysis
1993
Citation profile
214 federal appellate · 67 district · 11 state decisions
How this case has been cited
Cited by 487 later decisions (14 by the Supreme Court) — most recently June 2026 · most notably Morrison v. National Australia Bank Ltd. (2010), Hartford Fire Insurance Co v. California Merrett Underwriting Agency Management Limited (1993)
214 federal appellate · 67 district · 11 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.
Appellate journey
reviewedHaitian Centers Council, Inc. v. McNary (from Second Circuit Court of Appeals)
Relationships
Applies 14 U.S.C. § 89 · 8 U.S.C. § 1101 (§ 101 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1103 (§ 103 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1104 (§ 104 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1157 (§ 207 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1158 (§ 208 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1159 (§ 209 of the Immigration and Nationality Act of 1952 (McCarran-Walter)) · 8 U.S.C. § 1182 (§ 212 of the Immigration and Nationality Act of 1952 (McCarran-Walter))
Relies on Lujan v. Defenders of Wildlife · Immigration & Naturalization Service v. Cardoza-Fonseca · Plyler v. Doe · Immigration & Naturalization Service v. Doherty · Immigration & Naturalization Service v. Stevic
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 487 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Acts of Congress normally do not have extraterritorial application unless such an intent is clearly manifested.”
5 later decisions quote this exact passage · from the concurrence“Whenever the President finds that the entry of any aliens or of any class of aliens into the United States would be detrimental to the interests of the United States, he may by proclamation, and for such period as he shall deem necessary, suspend the entry of all aliens or any class of aliens as immigrants or nonimmigrants, or impose on the entry of aliens any restrictions he may deem to be appropriate.”
4 later decisions quote this exact passage · from the dissent“) sued several Government officials, including the President, the Acting Attorney General, and the Secretary of Homeland Security, in the United States District Court for the Northern District of California. The Organizations claimed that the Rule: (1) was improperly promulgated under 5 U.S.C. § 553 ; and (2) is an invalid exercise of the Attorney General's power under 8 U.S.C. § 1158 (b)(2)(C) because it is inconsistent with 8 U.S.C. § 1158 (a)(1). The Organizations moved immediately for a temporary restraining order (”
2 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.