Martin v. Lauer’s Empirical Analysis
686 F.2d 24 · 1982
Citation profile
22 federal appellate · 17 district · 5 state decisions
How this case has been cited
Cited by 57 later decisions — most recently September 2017 · most notably Jurgensen v. Fairfax County (1984), Camille Deloach v. Mitzi Bevers (1990)
22 federal appellate · 17 district · 5 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 5 U.S.C. § 2301 (Notification and Federal Employee Antidiscrimination and Retaliation Act of 2002)
Relies on Mt. Healthy City School District Board of Education v. Doyle · Pickering v. Board of Education of Township High School District 205 Will County Illinois · Boddie v. Connecticut · Upjohn Company v. United States · Chrysler Corporation v. Brown
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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A decision whether to release FOIA-exempt material ... requires a considered balancing of the public's interest in disclosure of particular material and the interests in non-disclosure acknowledged by the statutory exemptions.”
3 later decisions quote this exact passage · from the majority“[t]o the extent that matters are exempted from disclosure under exemption two on grounds of administrative burden, the exemption certainly does not represent a government interest in preventing employees from openly discussing such 'government information.' " Id. It also emphasized that this case involved only a limited disclosure to the plaintiffs' attorneys rather than public dissemination of information. Id. The court observed that there was no specific allegation that the attorneys would reveal the information publicly, and that means were available by which the government might prevent such public revelations. Id. at 34, 35. Hence, the court concluded that "a broad restriction, undermining the confidentiality of the attorney-client relationship and chilling discussions with counsel in order to protect the government's unclear interest in monitoring all discussions of FOIA-exempt information cuts too deeply into the employee's first amendment rights.”
2 later decisions quote this exact passage · from the concurrence“the government may protect its interest in prohibiting public disbursal of any sensitive information without intruding on the employee's substantial interest in freely discussing his legal rights with his attorney.”
2 later decisions quote this exact passage · from the concurrence
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.