Doe v. Civiletti’s Empirical Analysis
635 F.2d 88 · 1980
Citation profile
32 federal appellate · 10 district ·
How this case has been cited
Cited by 75 later decisions — most recently July 2021 · most notably Mack v. United States (1987), World Wide Minerals, Ltd. v. Republic of Kazakhstan (2002)
32 federal appellate · 10 district ·
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 Board of Regents of State Colleges v. Roth · Santobello v. New York · Bell v. Hood · Udall v. Tallman · United States v. Testan
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 75 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A person suffering legal wrong because of agency action is entitled to judicial review thereof. An action in a Court of the United States seeking relief other than money damages and stating a claim that an agency or an officer or employee thereof acted or failed to act in an official capacity or under color of legal authority shall not be dismissed nor relief therein be denied on the ground that it is against the United States or that the United States is an indispensable party.... Nothing herein (1) affects other limitations on judicial review or the power or duty of the court to dismiss any action or deny relief on any other appropriate legal or equitable ground; or (2) confers authority to grant relief if any other statute that grants consent to suit expressly or impliedly forbids the relief which is sought.”
2 later decisions quote this exact passage · from the majority“district courts shall have original jurisdiction of any action in the nature of mandamus to compel an officer or employee of the United States or any agency thereof to perform a duty owed to the plaintiff.”
2 later decisions quote this exact passage · from the majority“That [the attorney and agent] lacked the actual authority to bind the Government is fatal to Doe’s suit, for it is axiomatic that the United States is not bound by the unauthorized acts of its agents. “Whatever the form in which the Government functions, anyone entering into an arrangement with the Government takes the risk of having accurately ascertained that he who purports to act for the Government stays within the bounds of his authority.” Federal Crop Insurance Corp. v. Merrill, 332 U.S. 380, 384 , 68 S.Ct. 1, 3 , 92 L.Ed. 10 (1947). Undoubtedly, this “actual authority doctrine” may produce harsh results, and did so in Merrill-m which farmers whose crops were destroyed in a drought were denied reimbursement because the government agent who sold crop insurance to them was without actual authority to do so... . In spite of its rigor, the actual authority doctrine has been scrupulously followed. See, e. g., Dresser Industries, Inc. v. United States, 596 F.2d 1231 (5th Cir. 1979), cert. denied, 444 U.S. 1044 , 100 S.Ct. 731 , 62 L.Ed.2d 730 (1980); Jackson v. United States, 573 F.2d 1189 (Ct.Cl. 1978).”
1 later decision quote this exact passage · from the majority
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.