Day v. Wayne County Board of Auditors’s Empirical Analysis
749 F.2d 1199 · 1984
Citation profile
78 federal appellate · 34 district · 5 state decisions
How this case has been cited
Cited by 190 later decisions — most recently January 2024 · most notably Saulpaugh v. Monroe Community Hospital (1993), Poe v. Haydon (1988)
78 federal appellate · 34 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 20 U.S.C. § 1400 (Education for All Handicapped Children Act of 1975) · 28 U.S.C. § 636 · 42 U.S.C. § 1981 (Civil Rights Act of 1866) · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 1985 · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964) · 42 U.S.C. § 2000E (§ 704 of the Title VII of the Civil Rights Act of 1964) · 42 U.S.C. § 2000E (§ 706 of the Title VII of the Civil Rights Act of 1964)
Relies on Parratt v. Taylor · Preiser v. Rodriguez · Alexander v. Gardner-Denver Co. · Johnson v. Railway Express Agency, Inc. · Brown v. General Services Administration
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 190 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[w]here an employee establishes employer conduct which violates both Title VII and rights derived from another source-the Constitution or a federal statute-which existed at the time of the enactment of Title VII, the claim based on the other source is independent of the Title VII claim, and the plaintiff may seek the remedies provided by § 1983 in addition to those created by Title VII.”
10 later decisions quote this exact passage · from the majority“In establishing the applicability of Title VII to State and local employees, the Committee wishes to emphasize that the individual’s right to file a civil action in his own behalf, pursuant to the Civil Rights Act of 1870 and 1871, 42 U.S.C. §§ 1981 and 1983, is in no way affected ____ Title VII was envisioned as an independent statutory authority meant to provide an aggrieved individual with an additional remedy to redress employment discrimination____ The bill, therefore, by extending jurisdiction to State and local government employees does not affect existing rights that such individuals have already been granted by previous legislation.”
3 later decisions quote this exact passage · from the majority“'it would be anomalous to hold that when the only unlawful employment practice consists of the violation of a right created by Title VII, the plaintiff can bypass all of the administrative processes of Title VII and go directly into court under § 1983.'”
2 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.