Brown v. Frey’s Empirical Analysis
807 F.2d 1407 · 1986
Citation profile
29 federal appellate · 1 district · 7 state decisions
How this case has been cited
Cited by 47 later decisions — most recently August 2018 · most notably Forbes v. Trigg (1992), Viens v. Daniels (1989)
29 federal appellate · 1 district · 7 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 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Morrissey v. Brewer · Wolff v. McDonnell · Superintendent Massachusetts Correctional Institution Walpole v. Hill · Baxter v. Palmigiano · United States v. Albertini
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“written statement, even though 'sparse in content,' is 'sufficient to inform [the inmate] of the evidence relied upon by the factfinders' ") (citations omitted). 18 Here, the Hawaii prison rules grant Mujahid the right to be provided a summary of the evidence the Committee relied upon and a summary of its findings. The Committee's one-sentence statement that it relied upon "the evidence and testimonies presented”
2 later decisions quote this exact passage · from the majority“Ascertaining whether this standard is satisfied does not require examination of the entire record, independent assessment of the credibility of witnesses, or weighing of the evidence.”
2 later decisions quote this exact passage · from the majority“[T]he balance between the penological interest in avoiding excessive administrative burdens in order to use disciplinary proceedings to assure institutional safety and promote rehabilitation, on the one hand, and the interests of the individual inmate, on the other, is such that the due process clause does not require “technical and detailed disciplinary reports.” The requirement is satisfied if the written statement, even though “sparse in content,” is “sufficient to inform [the inmate] of the evidence relied upon by the factfinders in reaching their decision to take disciplinary action.” This ensures that disciplinary [committees] will not act arbitrarily, and it forces a disciplinary [committee] to commit itself, contemporaneously with its decision, to certain evidence, thus allowing a reviewing body to fairly and accurately review the incident that led to the proceeding or the proceeding itself. After this, due process requires no more, and it certainly does not dictate that we expose a disciplinary [committee’s] written statement to such extensive scrutiny that we fail to adequately respect “the legitimate institutional needs of assuring the safety of inmates and prisoners, avoiding burdensome administrative requirements that might be susceptible to manipulation, and preserving the disciplinary process as a means of rehabilitation.””
1 later decision quote this exact passage · from the majoritye.g. Speller v. State
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.