Parks v. Pavkovic’s Empirical Analysis
753 F.2d 1397 · 1985
Citation profile
88 federal appellate · 5 district · 12 state decisions
How this case has been cited
Cited by 164 later decisions — most recently June 2025 · most notably United States v. Martinson (1987), State ex rel. White v. Cuyahoga Metropolitan Housing Authority (1997)
88 federal appellate · 5 district · 12 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) · 20 U.S.C. § 1401 · 20 U.S.C. § 1412 · 20 U.S.C. § 1415 · 28 U.S.C. § 1291 · 28 U.S.C. § 1292 · 29 U.S.C. § 701 (Employment Opportunities for Individuals With Disabilities Act) · 29 U.S.C. § 794
Relies on Parklane Hosiery Co. v. Shore · Board of Education of Hendrick Hudson Central School District Bd of Ed Westchester County v. Rowley · Quern v. Jordan · Sosna v. Iowa · United States Parole Commission v. Geraghty
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 164 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“if the determination of damages will be mechanical and uncontroversial, so that the issues the defendant wants to appeal before that determination is made are very unlikely to be mooted or altered by it--in legal jargon, if only a 'ministerial' task remains for the district court to perform--then immediate appeal is allowed.”
4 later decisions quote this exact passage · from the majority“computing the money owed... is unlikely to engender dispute or controversy, and will require no analytic or judgmental determinations that might... give rise to other appealable questions”
3 later decisions quote this exact passage · from the majority“In the first, a deaf and blind child, perfectly capable of living at home, is institutionalized on the basis of a judgment that he can get a better education in a more controlled environment. His living expenses in the institution would be expenses of his special education within the meaning of the Act and his parents would be entitled to reimbursement for them. In our second hypothetical case, the child is in a coma, and is institutionalized because he cannot be cared for at home. We understand the plaintiffs to be conceding ... that since the child would be completely uneducable in his condition— since he could not benefit from special education no matter how expensive — his living expenses in the institution would not be chargeable to the state under the Act. In the third case, an intermediate case ... the child cannot be cared for at home because of some purely physical problem, but, because of that problem, neither can he be educated unless he is institutionalized. Maybe he requires continuous medical attention which he could not get in a regular day school. So he must be institutionalized for education reasons but equally for medical reasons____ [T]he courts that have considered the question have rejected the argument that a state can avoid its obligations under the Act by showing that the child would have to be institutionalized quite apart from educational needs that also required institutionalization.”
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.