Ruiz v. Cady’s Empirical Analysis
660 F.2d 337 · 1981
Citation profile
7 federal appellate · 2 district · 2 state decisions
How this case has been cited
Cited by 23 later decisions — most recently July 2010
7 federal appellate · 2 district · 2 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 Fay v. Noia · Browder v. Director Department of Corrections of Illinois · Sandstrom v. Montana · Earley v. DiCenso · Allen v. Perini
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A default judgment, without full inquiry into the merits, is especially rare when entered against a custodian in a habeas corpus proceeding. Although such a remedy is extreme, ... we think it should be preserved as a sanction against a respondent's unwarranted delay. Where the respondent is guilty of long and inadequately explained delays, it may be presumed that the petitioner is being illegally confined.... In those situations, the petitioner's due process rights would be denied, and '[t]he writ of habeas corpus, challenging illegality of detention, ... reduced to a sham if the trial courts [did] not act within a reasonable time....' " 8 Id. at 340. The delay in Ruiz was part of a pattern. Nonetheless, the court reversed the grant of default judgment because, in the particular case before it, the Government had actually delayed resolution of the petitioner's claims by only five days. The court held, "[t]his relatively short delay, certainly of some consequence if the petitioner has been wrongly confined, does not, in our opinion rise to the level of a due process violation. Ruiz has not shown or argued any substantial personal harm from the delay.”
1 later decision quote this exact passage · from the majoritye.g. Stines v. Martin“the respondent is guilty of long and inadequately explained delays, it may be presumed that applicant is being illegally confined.” Id., at 340 . The court made this argument with a full understanding of the consequences of entering default judgement, recognizing that”
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.