John M. Bates v. Harold E. Sponberg’s Empirical Analysis
547 F.2d 325 · 1976
Citation profile
38 federal appellate · 11 district · 11 state decisions
How this case has been cited
Cited by 85 later decisions — most recently April 2025 · most notably Bailey v. Floyd County Board of Education ex rel. Towler (1997), Mangels v. Pena (1986)
38 federal appellate · 11 district · 11 state decisions — followed in 10 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.
Relationships
Relies on Edelman v. Jordan · Wood v. Strickland · Patterson v. United States · United States Accardi v. Shaughnessy · Service v. Dulles
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 85 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"While courts have generally invalidated adjudicatory actions by federal agencies which violated their own regulations promulgated to give a party a procedural safeguard, we conclude that the basis for such reversals is not, as Bates asserts, the Due Process Clause, but rather a rule of administrative law.... Agency actions in Yellin v. United States, supra, and Accardi v. Shaughnessy, supra, were reversed for violations of their own regulations, but the court did not rely on the due process clause.””
19 later decisions quote this exact passage · from the majority“the crux of the issue, in terms of due process under the Fourteenth Amendment, is not whether the due process hearing to which Professor Bates may have been entitled was held in the presence of the authority having final responsibility to determine his discharge, but instead whether the hearing accorded him was meaningful.”
5 later decisions quote this exact passage · from the majority““According to the opinion in the leading first Morgan case, the requirement is not that deciding officers must personally read the record but it is that they must personally ‘consider and appraise’ the evidence. The Court declared: ‘Evidence may be taken by an examiner. Evidence thus taken may be sifted and analyzed by competent subordinates.’ Since the only purpose of sifting and analyzing of evidence by subordinates is to save the time of the deciding officers, this necessarily means that deciding officers may ‘consider and appraise’ the evidence by reading a summary or analysis prepared by subordinates. The Supreme Court thus did not require in the First Morgan case that deciding officers must read all the evidence or even that they must directly read any of it. The requirement has to do with personal understanding of the evidence, not with the mechanics by which the understanding is developed. In common practice, deciding officers develop their understanding of evidence not only through reports of subordinates but especially through summaries and explanations and briefs and oral arguments of parties.””
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.