Fitzgerald v. Mountain Laurel Racing, Inc.’s Empirical Analysis
607 F.2d 589 · 1979
Citation profile
38 federal appellate · 11 district · 3 state decisions
How this case has been cited
Cited by 97 later decisions — most recently February 2018 · most notably Continental Group, Inc. v. Amoco Chemicals Corp. (1980), Arthur Treacher's Franchisee Litigation v. A & B Management Corporation (1982)
38 federal appellate · 11 district · 3 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. § 1292 · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Board of Regents of State Colleges v. Roth · Paul v. Davis · Bishop v. Wood · Bowman Transportation, Inc. v. Arkansas-Best Freight System, Inc. · Boddie v. Connecticut
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 97 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Mountain Laurel protests that the State had no authority-to enforce the terms of the stall agreement and that the State did not “put its weight” behind the eviction. Mountain Laurel’s argument misses the critical features of this case: the presiding racing judge and racing secretary, acting in their official capacities, [participated in the decision to expel Fitzgerald. In so doing, the racing officials “put their weight” behind the challenged expulsion by telling Mountain Laurel that Fitzgerald was violating Commission Rules and by approving the ensuing expulsion. In the present case ... the State did more than merely adopt a regulation prohibiting inconsistent driving. Officials of the Racing Commission personally and actively participated in the specific conduct challenged by Fitzgerald. Their opinion as “racing officials and judges” of Fitzgerald’s conduct precipitated the ensuing summary expulsion. ... [W]e conclude that the totality of the circumstances demonstrate that Mountain Laurel’s eviction of Fitzgerald must be fairly considered as the disciplinary act of the State.”
4 later decisions quote this exact passage · from the majority“must be recognized as a joint participant in the challenged activity.”
3 later decisions quote this exact passage · from the majority“because the nature of harness racing is such that no adequate remedy exists at law to compensate [them] for losses to income and reputation sustained from an unlawful suspension.”
2 later decisions quote this exact passage · from the majoritye.g. Charles Crissman · Crissman
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.