Saenz v. Playboy Enterprises, Inc.’s Empirical Analysis
841 F.2d 1309 · 1988
Citation profile
14 federal appellate · 11 state decisions
How this case has been cited
Cited by 32 later decisions — most recently August 2024 · most notably Bentley v. Bunton (2002), 626 So. 2d 345 - Sassone v. Elder (1993)
14 federal appellate · 11 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
Relies on Anderson v. Liberty Lobby, Inc. · New York Times Co. v. Sullivan · First Nat. Bank of Ariz. v. Cities Service Co. · Gertz v. Robert Welch, Inc. · St. Amant v. Thompson
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]e believe that an official should not be allowed to transform governmental criticism into personal defamation where none exists. We also do not believe, however, that a publisher may, without impediment of law, trammel a public official by “surreptitious and insidious implication” under the pretense of governmental critique. To deny a public official the opportunity to demonstrate the defamatory innuendo of a publication, even one critical of governmental conduct, is to open Pandora’s Box from which countless evils may spring. A legal fiction denying the existence of clearly discernable, though not explicit charges, exposes public officials to baseless accusations and public mistrust while promoting an undisciplined brand of journalism both unproductive to society and, as we see it, unprotected by constitutional considerations.”
1 later decision quote this exact passage“And the U.S. adviser who had been Mi-trione’s predecessor for four years, whose office was on the first floor of the Montevideo jefatura, where torture reportedly took place and the screams of the victims reverberated, who by his own account had intimate and influential relations with the Uruguayan police, was Adolph Saenz. From Montevideo, allegations of torture by his police clients would follow Saenz through subsequent assignments ....”
1 later decision quote this exact passagee.g. Bentley v. Bunton“[n]ot only must the plaintiff establish that *Page 1125 the statement is susceptible of a defamatory meaning which the defendants knew to be false or which the defendants published with reckless disregard for its potential falsity, but also that the defendants intended to imply or were reckless toward the implications.”
1 later decision quote this exact passage
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.