Cianci v. New Times Publishing Company’s Empirical Analysis
639 F.2d 54 · 1980
Citation profile
52 federal appellate · 15 district · 63 state decisions
How this case has been cited
Cited by 168 later decisions (1 by the Supreme Court) — most recently March 2026 · most notably Milkovich v. Lorain Journal Co. (1990), Strada v. Connecticut Newspapers, Inc. (1984)
52 federal appellate · 15 district · 63 state decisions — followed in 28 states
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 Klaxon Co. v. Stentor Electric Manufacturing Co. · New York Times Co. v. Sullivan · Gertz v. Robert Welch, Inc. · St. Amant v. Thompson · Douglas v. Alabama
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 168 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If a speaker says, 'In my opinion John Jones is a liar,' he implies a knowledge of facts which lead to the conclusion that Jones told an untruth. Even if the speaker states the facts upon which he bases his opinion, if those facts are either incorrect or incomplete, or if his assessment of them is erroneous, the statement may still imply a false assertion of fact. Simply couching such statements in terms of opinion does not dispel these implications; and the statement, 'In my opinion Jones is a liar,' can cause as much damage to reputation as the statement, 'Jones is a liar.' As Judge Friendly aptly stated: '[It] would be destructive of the law of libel if a writer could escape liability for accusations of [defamatory conduct] simply by using, explicitly or implicitly, the words "I think."'”
9 later decisions quote this exact passage · from the majority“Under the First Amendment there is no such thing as a false idea. However pernicious an opinion may seem, we depend for its correction not on the conscience of judges and juries but on the competition of other ideas. But there is no constitutional value in false statements of fact.”
5 later decisions quote this exact passage · from the majority““A defamatory communication may consist of a statement in the form of an opinion, but a statement of this nature is actionable only if it implies the allegation of undisclosed defamatory facts as the basis for the opinion.””
5 later decisions 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.