Goodman v. Harris County’s Empirical Analysis
571 F.3d 388 · 2009
Citation profile
17 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 92 later decisions — most recently June 2025 · most notably Zarnow v. City of Wichita Falls (2010), RSR Corp. v. International Insurance (2010)
17 federal appellate · 1 district · 2 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
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 · Daubert v. Merrell Dow Pharmaceuticals, Inc. · Graham v. Connor · City of Canton v. Harris
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 92 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A]n official capacity suit is, in all respects other than name, to be treated as against the entity. It is not against the official personally, for the real party in interest is the entity.”
2 later decisions quote this exact passage · from the majority“For an official to act with deliberate indifference, the official must both be aware of facts from which the inference could be drawn that a substantial risk of serious harm exists, and he must also draw the inference.” To establish deliberate indifference, “a plaintiff usually must demonstrate a pattern of violations and that the inadequacy of. the training is obvious and obviously likely to result in a constitutional violation.” Where a plaintiff fails to establish deliberate indifference, the court need not address the other two prongs of supervisor liability. Furthermore, “for a supervisor to be liable for failure to train, the focus must be on the adequacy of the training program in relation to the tasks the particular officers must perform.” Moreover, “for liability to attach based on an ‘inadequate training’ claim, a plaintiff must allege with specificity how a particular training program is defective.””
1 later decision quote this exact passage · from the majority“a well-pleaded complaint may proceed even if it strikes a savvy judge that actual proof of those facts is improbable, and 'that a recovery is very remote and unlikely.' " Id. at 556 , 127 S.Ct. 1955 (quoting Scheuer v. Rhodes , 416 U.S. 232 , 236, 94 S.Ct. 1683 , 40 L.Ed.2d 90 (1974) ). 2. Qualified Immunity "The doctrine of qualified immunity shields government officials acting within their discretionary authority from liability when their conduct does not violate clearly established statutory or constitutional law of which a reasonable person would have known.”
1 later decision quote this exact passage · from the majoritye.g. Ramirez v. Fonseca
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.