Heitmanis v. Austin’s Empirical Analysis
899 F.2d 521 · 1990
Citation profile
11 federal appellate · 2 state decisions
How this case has been cited
Cited by 28 later decisions — most recently August 2025 · most notably Rouse v. Daimlerchrysler Corp. (2002), Baskin v. Bath Township Board of Zoning Appeals (1994)
11 federal appellate · 2 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 Moses H. Cone Memorial Hospital v. Mercury Construction Corp. · Baker v. Carr · Colorado River Water Conservation District v. United States · Railroad Commission v. Pullman Co. · Lugar v. Edmondson Oil Co.
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) whether the state court has assumed jurisdiction over any res or property; (2) whether the federal forum is less convenient to the parties; (3) avoidance of piecemeal litigation; and (4) the order in which jurisdiction was obtained .... (5) whether the source of governing law is state or federal; (6) the adequacy of the state court action to protect the federal plaintiffs rights; (7) the relative progress of the state and federal proceedings; and, (8) the presence or absence of concurrent jurisdiction. These factors, however, do not comprise a mechanical checklist. Rather, they require “a careful balancing of the important factors as they apply in a give[n] case” depending on the particular facts at hand.”
1 later decision quote this exact passage · from the majority“[t]he key issue in deciding whether abstention was proper is whether complete relief was obtained in state court; if so, then the court properly abstained from deciding the case.... ... [I]n the instant case, the [state] court considered the constitutional arguments only briefly in its oral decision. Its curt mention of the constitutional question demonstrates the inadequacy of the state forum. Thus, due to the additional issues raised in the federal complaint and the failure of the state court to adequately address the constitutional questions, we conclude that the district court should not have abstained under the Colorado River doctrine.”
1 later decision quote this exact passage · from the majority“[b]y requiring the county executive committees to be made up of an equal number of elected delegates and legislators, the Election Law directly controls the internal structure of the political parties.”
1 later decision 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.