Hecht v. Commerce Clearing House, Inc.’s Empirical Analysis
897 F.2d 21 · 1990
Citation profile
71 federal appellate · 27 district · 3 state decisions
How this case has been cited
Cited by 359 later decisions (2 by the Supreme Court) — most recently January 2023 · most notably Beck v. Prupis (2000), First Nationwide Bank v. Gelt Funding Corp. (1994)
71 federal appellate · 27 district · 3 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 18 U.S.C. § 1341 (White-Collar Crime Penalty Enhancement Act of 2002) · 18 U.S.C. § 1343 · 18 U.S.C. § 1961 (§ 901 of the Racketeer Influenced and Corrupt Organizations Act) · 18 U.S.C. § 1962 (§ 901 of the Racketeer Influenced and Corrupt Organizations Act) · 18 U.S.C. § 1964 (§ 901 of the Racketeer Influenced and Corrupt Organizations Act)
Relies on Perry v. Sindermann · Sedima Sprl v. Imrex Company Inc · Alexander v. United States · McKesson Corp. v. Division of Alcoholic Beverages & Tobacco · Rose 88-1634 v. Bartle a Reed W 88-1646
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 359 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Central to the notion of proximate cause [under RICO] is the idea that a person is not liable to all those who may have been injured by his conduct, but only to those with respect to whom his acts were `a substantial factor in the sequence of responsible causation,' and whose injury was `reasonably foreseeable or anticipated as a natural consequence.'”
18 later decisions quote this exact passage · from the majority“(1) a violation of section 1962; (2) injury to business or property; and (3) causation of the injury by the violation.”
10 later decisions quote this exact passage · from the majority“Because a plaintiff must show injury ‘by the conduct constituting the violation’ of RICO, the injury must be caused by a pattern of racketeering activity violating section 1962 or by individual RICO predicate acts. Moreover, the RICO pattern or acts must proximately cause plaintiffs injury. By itself, factual causation (e.g., ‘cause-in-fact’ or ‘but for’ causation) is not sufficient.... For our purposes, the RICO pattern or acts proximately cause a plaintiffs injury if they are a substantial factor in the sequence of responsible causation, and if the injury is reasonably foreseeable or anticipated as a natural consequence.”
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.