Jacobs v. Frank’s Empirical Analysis
1991
Citation profile
2 federal appellate · 169 state decisions
How this case has been cited
Cited by 206 later decisions — most recently February 2026 · most notably 116 Ohio App. 3d 195 - Gosden v. Louis (1996), 81 Ohio App. 3d 591 - Akron-Canton Waste Oil, Inc. v. Safety-Kleen Oil Services, Inc. (1992)
2 federal appellate · 169 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
Relies on New York Times Co. v. Sullivan · Milkovich v. Lorain Journal Co. · Dames & Moore v. Regan · Dupler v. Mansfield Journal Co. · Preston v. Murty
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 206 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“acting with knowledge that the statements are false or acting with reckless disregard as to their truth or falsity.”
16 later decisions quote this exact passage“Actual malice 'cannot be implied from the character and content of a publication. * * * It is not sufficient for a libel plaintiff to show that an interpretation of facts is false; rather, he must prove with convincing clarity that defendant was aware of the high probability of falsity.'”
10 later decisions quote this exact passage““ ‘A publication is conditionally or qualifiedly privileged where circumstances exist, or are reasonably believed by the defendant to exist, which cast on him the duty of making a communication to a certain other person to whom he makes such communication in the performance of such duty, or where the person is so situated that it becomes right in the interests of society that he should tell third persons certain facts, which he in good faith proceeds to do. This general idea has been otherwise expressed as follows: A communication made in good faith on any subject matter in which the person communicating has an interest, or in reference to which he has a duty, is privileged if made to a person having a corresponding interest or duty, even though it contains matter which, without this privilege, would be actionable, and although the duty is not a legal one, but only a moral or social duty of imperfect obligation. The essential elements of a conditionally privileged communication may accordingly be enumerated as good faith, an interest to be upheld, a statement limited in its scope to this purpose, a proper occasion, and publication in a proper manner and to proper parties only. The privilege arises from the necessity of full and unrestricted communication concerning a matter in which the parties have an interest or duty, and is not restricted within any narrow limits. * * * ’ “The concept of a qualified privilege is based upon public policy and the need to protect the publicat”
9 later decisions 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.