Brown v. Vaughn’s Empirical Analysis
1991
Citation profile
9 state decisions
How this case has been cited
Cited by 10 later decisions — most recently February 2011
9 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. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964)
Relies on Meritor Savings Bank, FSB v. Vinson · Rabidue v. Osceola Refining Co. · Consolidated Gold Fields PLC v. Minorco, S.A. · Laughlin v. Breaux · Wilson v. Hibernia Nat. Bank
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The type of conduct constituting such [hostile environment] harassment includes unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature.... Every act of harassment, although reprehensible, does not necessarily give rise to a hostile environment claim. To be actionable, the harassment must be sufficiently severe or pervasive as to alter the conditions of the victim's employment and create an abusive, hostile environment. Meritor, [ 477 U.S. at 63-66 ] 106 S.Ct. at 2404-5 . In general, hostile environment harassment is characterized by multiple and varied incidents of offensive conduct which have the cumulative effect of creating a hostile working environment for the employee thus victimized. See Rabidue v. Osceola Refining Co., 805 F.2d 611, 620 (6th Cir.1986).”
2 later decisions quote this exact passage“harassment exists when an employer places unwanted terms or conditions on employment, benefits or other employment advantages in exchange for sexual favors. A”
2 later decisions quote this exact passage“In Laughlin , this panel held that although several different incidents of physical abuse combined to produce the plaintiff's Battered Woman's Syndrome, each instance of physical abuse constituted a separate assault and battery giving rise to a separate cause of action, so that prescription ran as to each assault and battery from the time of its occurrence. Laughlin, 515 So.2d at 482 . The present case is clearly distinguishable in view of our conclusion that each of the alleged incidents of Vaughn's misconduct, in contrast to Laughlin where each assault and battery was clearly a separate tort, did not constitute a separate cause of action for harassment, but rather, that it was the pattern of harassment which gave rise to plaintiffs' hostile environment claim.”
1 later decision quote this exact passage
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.