Fernandez v. Trias Monge’s Empirical Analysis
586 F.2d 848 · 1978
Citation profile
23 federal appellate · 9 district · 2 state decisions
How this case has been cited
Cited by 49 later decisions (2 by the Supreme Court) — most recently March 2023 · most notably Allen v. McCurry (1980), Pulliam v. Allen (1984)
23 federal appellate · 9 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 28 U.S.C. § 1738 · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Younger v. Harris · Monroe v. Pape · Gault · Railroad Commission v. Pullman Co. · Gerstein v. Pugh
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The District Court correctly held that respondents’ claim for relief was not barred by the equitable restrictions on federal intervention in state prosecutions, Younger v. Harris ... the injunction was not directed at the state prosecutions as such, but only at the legality of pretrial detention without a judicial hearing, an issue that could not be raised in defense of the criminal prosecution. The order to hold preliminary hearings could not prejudice the conduct of the trial on the merits.”
1 later decision quote this exact passage · from the majoritye.g. Coleman v. Stanziani“As a general rule, this Circuit accords state court decisions of federal constitutional claims res judicata effect in subsequent § 1983 actions ... The easiest application of the res judicata bar involves a federal plaintiff who seeks to relitigate the identical constitutional claim he, as a state plaintiff, sued upon and lost in state court. Fernandez v. Trias Monge, 586 F.2d 848, 854 (1st Cir.1978) (emphasis added).”
1 later decision quote this exact passage · from the dissent“[T]o bar all claims that [m]ight have been raised in a criminal trial forces the criminal defendant to the uncomfortable choice between, on the one hand, possibly alienating the trial judge, particularly when the trial judge's own procedures are questioned, and delaying trial, and on the other, foregoing his constitutional claim.”
1 later decision quote this exact passage · from the concurrence
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.