Grosvenor v. Brienen’s Empirical Analysis
801 F.2d 944 · 1986
Citation profile
25 federal appellate · 2 district · 5 state decisions
How this case has been cited
Cited by 61 later decisions — most recently July 2022 · most notably Webb v. James (1998), Magnuson v. Video Yesteryear (1996)
25 federal appellate · 2 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 28 U.S.C. § 2072 · 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 1988
Relies on Hensley v. Eckerhart · Carey v. Piphus · Christiansburg Garment Co. v. Equal Employment Opportunity Commission · Hughes v. Rowe · Newman v. Piggie Park Enterprises, Inc.
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“At any time more than 10 days before the trial begins, a party defending against a claim may serve upon the adverse party an ■ offer to allow judgment to be taken against the defending party for the money or property or to the effect specified in the offer, with costs then accrued. If within 10 days after the service of the offer the adverse party serves written notice that the offer is accepted, either party may then file the offer and notice of acceptance together with proof of service thereof and thereupon the clerk shall enter judgment. An offer not accepted shall be deemed withdrawn and evidence thereof is not admissible except in a proceeding to determine costs. If the judgment finally obtained by the offeree is not more favorable than the offer, the offeree must pay the costs incurred after the making of the offer.”
4 later decisions quote this exact passage · from the majority“Thus, although Rule 68 does not specify that an offer of judgment be in writing, the requirement that the offer be served upon the plaintiff makes no sense unless it means that the offer must be written.”
3 later decisions quote this exact passage · from the majoritye.g. 817 F. Supp. 1237 - Strauss v. Springer · Thomas Clark Nancy Clark v. Edgar Sims, Jr. Jeanette I. Sims, General Partners of Kdca Partnership, a Maryland General Partnership Maryland Hospitality, Incorporated, and Andrew M. Sims, A/K/A Best Western Maryland Inn, Thomas Clark Nancy Clark v. Maryland Hospitality, Incorporated, and Edgar Sims, Jr. Jeanette I. Sims, General Partners of Kdca Partnership, a Maryland General Partnership Andrew M. Sims, A/K/A Best Western Maryland Inn“[A]t the time an offer is made, the plaintiff knows the amount in damages caused by the challenged conduct. The plaintiff also knows, or can ascertain, the costs then accrued. A reasonable determination whether to accept the offer can be made by simply adding these two figures and comparing the sum to the amount of-fered____ [Pjostoffer costs merely offset part of the expense of continuing the litigation to trial, and should not be included in the calculus.”
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.