Spain v. Mountanos’s Empirical Analysis
690 F.2d 742 · 1982
Citation profile
60 federal appellate · 6 district · 9 state decisions
How this case has been cited
Cited by 101 later decisions — most recently January 2022 · most notably Berger v. Heckler (1985), In re Nucorp Energy, Inc. (1985)
60 federal appellate · 6 district · 9 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 15 U.S.C. § 15 (§ 4 of the Clayton Antitrust Act of 1914) · 28 U.S.C. § 1961 · 42 U.S.C. § 1988
Relies on Hutto v. Finney · Maher v. Gagne · Cooper v. Aaron · Zurcher v. Stanford Daily · Griffin v. County School Board of Prince Edward County
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 101 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[U]nder the extraordinary circumstances here where the judgment is against a state, which refuses to appropriate funds through the normal process provided by state law, the district court should not necessarily be reduced to satisfying a judgment through the cumbersome procedure of attempting to execute against state property or bank accounts. It may, instead, pursue any remedy provided in Rule 69 or Rule 70 to enforce the award, including ordering state officials to pay the claim.”
3 later decisions quote this exact passage · from the majority“[A] state cannot frustrate the intent of section 1988 by setting up state law barriers to block enforcement of an attorney's fees award.”
2 later decisions quote this exact passage · from the majority““[W]here a state expresses its unwillingness to comply with a valid judgment of a federal district court, the court may use any of the weapons generally at its disposal to ensure compliance.... ‘The issue here is not one of judicial confrontation with the state. It is one of implementation of a Congressional mandate’ ... The italicized words provide the key. Congress has declared that states and their officials who violate federal civil rights laws must reimburse the successful plaintiff for costs incurred in seeking redress. To strike down the order in this case because it conflicts with the laws of Mississippi would be no different than reversing a bare judgment for attorney’s fees. In either case, we would be allowing the state by legislative action, to recloak itself with the Eleventh Amendment immunity which Congress has chosen to remove. Such a result would be contrary to the command of the Supremacy Clause of the United States Constitution(latter emphasis added)”
1 later decision quote this exact passage · from the majoritye.g. Duran v. Lamm
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.