Halderman v. Pennhurst State School & Hospital’s Empirical Analysis
673 F.2d 628 · 1982
Citation profile
61 federal appellate · 9 district · 1 state decisions
How this case has been cited
Cited by 120 later decisions (1 by the Supreme Court) — most recently July 2024 · most notably Pennhurst State School and Hospital v. Halderman (1984), United States v. Grier (2007)
61 federal appellate · 9 district · 1 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 Singleton v. Wulff · Ohio Bureau of Employment Services v. Hodory · United States v. United Mine Workers of America · Pennhurst State School and Hospital v. Halderman · Shillitani v. United States
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 120 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[B]y resorting to self-help in a situation where a post-judgment change in the law is arguably a reason for relief from the judgment, a party subject to that judgment deprives the other side of the notice and opportunity to be heard which Rule 60(b) would otherwise require, and of the protection of the provision in that rule____The rule contemplates consideration by the trial court of the competing equities, of the strengths and weaknesses of the parties’ positions, and of the imposition of conditions for relief from a judgment----The self-help route leaves the trial court with no alternative except restoration of the status quo ante bellum by a coercive contempt order.”
1 later decision quote this exact passage · from the majority“[a]t the time the [Commonwealth] made the deliberate and considered choice to advise the Court that it intended to disobey the [district court’s] payment order it was open to th[e] defendant] to move before the District Court under Rule 60(b)(5) or (6) for relief... on the ground that the action of the Pennsylvania legislature justified relieving the Commonwealth from the obligation there imposed.”
1 later decision quote this exact passage · from the majority“the reversal of the [underlying injunction] does more than destroy the future sanction of the decree. It adjudges that it never should have passed; that the right which it affected to create was no right at all. To let the liability stand for past contumacy would be to give the plaintiff a remedy not for a right but for a wrong, which the law should not do.”
1 later decision quote this exact passage · from the concurrencee.g. Gregory v. Depte
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.