Waters v. Churchill’s Empirical Analysis
1994
Citation profile
734 federal appellate · 214 district · 181 state decisions
How this case has been cited
Cited by 1,910 later decisions (25 by the Supreme Court) — most recently August 2024 · most notably Garcetti v. Ceballos (2006), Engquist v. Oregon Department of Agriculture (2008)
734 federal appellate · 214 district · 181 state decisions — followed in 30 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
reviewedthe decision below (from Seventh Circuit Court of Appeals)
Relationships
Applies 42 U.S.C. § 1981 (Civil Rights Act of 1866) · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on McDonnell Douglas Corp. v. Green · Board of Regents of State Colleges v. Roth · Universal Camera Corp. v. National Labor Relations Board · United States v. Leon · New York Times Co. v. Sullivan
Cited together with Connick v. Myers · Pickering v. Board of Education of Township High School District 205 Will County Illinois · Rankin v. McPherson · Mt. Healthy City School District Board of Education v. Doyle · 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 1,910 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The government's interest in achieving its goals as effectively and efficiently as possible is elevated from a relatively subordinate interest when it acts as sovereign to a significant one when it acts as employer. The government cannot restrict the speech of the public at large just in the name of efficiency. But where the government is employing someone for the very purpose of effectively achieving its goals, such restrictions may well be appropriate.”
100 later decisions quote this exact passage · from the concurrencee.g. William E. Foster, and Cross v. City of Southfield, a Municipal Corporation, Janet Tobin, Personal Representative of the Estate of Rollin G. Tobin, Deceased, and Robert Block, Its Agents, Officers and Employees, Jointly and Severally, and Cross William E. Foster v. City of Southfield, a Municipal Corporation, Janet Tobin, Personal Representative of the Estate of Rollin G. Tobin, Deceased, and Robert Block, Its Agents, Officers and Employees, Jointly and Severally · Burnham v. Ianni“balance between the interests of the [employee], as a citizen, in commenting upon matters of public concern and the interest of the State, as an employer, in promoting the efficiency of the public services it performs through its employees.”
45 later decisions quote this exact passagee.g. William E. Foster, and Cross v. City of Southfield, a Municipal Corporation, Janet Tobin, Personal Representative of the Estate of Rollin G. Tobin, Deceased, and Robert Block, Its Agents, Officers and Employees, Jointly and Severally, and Cross William E. Foster v. City of Southfield, a Municipal Corporation, Janet Tobin, Personal Representative of the Estate of Rollin G. Tobin, Deceased, and Robert Block, Its Agents, Officers and Employees, Jointly and Severally · Burnham v. Ianni“look to the facts as the employer reasonably found them to be,”
24 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.