O'Neill v. Krzeminski’s Empirical Analysis
839 F.2d 9 · 1988
Citation profile
76 federal appellate · 39 district · 7 state decisions
How this case has been cited
Cited by 269 later decisions — most recently January 2022 · most notably Martinez v. Colon (1995), Ricciuti v. N.Y.C. Transit Authority (1997)
76 federal appellate · 39 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 Daniels v. Williams · Smith v. Wade · City of Newport v. Fact Concerts, Inc. · Davidson v. Cannon · Johnson v. Glick
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 269 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A law enforcement officer has an affirmative duty to intercede on the behalf of a citizen whose constitutional rights are being violated in his presence by other officers.”
8 later decisions quote this exact passage · from the majority“Even when the evidence is viewed in the light most favorable to the plaintiff, there is insufficient evidence to permit a jury reasonably to conclude that Connors’ failure to intercede was a proximate cause of the beating. The three blows were struck in such rapid succession that Connors had no realistic opportunity to prevent them. This was not an episode of sufficient duration to support a conclusion that an officer who stood by without trying to assist the victim became a tacit collaborator. With respect to the subsequent dragging of O’Neill across the floor, however, the case against Connors is adequate to create an issue of fact for the jury. Having seen the victim beaten, he was alerted to the need to protect O’Neill from further abuse.”
7 later decisions quote this exact passage · from the majority“'the award is so high as to shock the judicial conscience and constitute a denial of justice.'”
6 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.