Ulaleo v. Paty’s Empirical Analysis
902 F.2d 1395 · 1990
Citation profile
17 federal appellate · 12 district · 4 state decisions
How this case has been cited
Cited by 47 later decisions — most recently August 2015 · most notably Pele Defense Fund v. Paty (1992), Native Village of Noatak v. Blatchford (1994)
17 federal appellate · 12 district · 4 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 Ex Parte: Edward T Young · Edelman v. Jordan · Pennhurst State School and Hospital v. Halderman · Kentucky v. Graham · Papasan v. Allain
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.
“The Complaint is that sometime in the past, the BLNR undertook an action, the land exchange, which allegedly injured the plaintiffs by violating the trust of which the plaintiffs are beneficiaries. . . . The immediate relief plaintiffs seek would require the state to purchase the lands from its present holder by way of cash or other land. We hold that to grant the requested relief would be a retrospective remedy .... If the tmst duty was violated, it happened when the BLNR executed the exchange.”
3 later decisions quote this exact passage · from the majority“The distinction between a continuing obligation on the part of the trustee and an ongoing liability for past breach of trust is essentially a formal distinction of the sort we rejected in [Edelman v. Jordan ] .......We discern no substantive difference between a not-yet-extinguished liability for a past breach of trust and the continuing obligation to meet trust responsibilities asserted by the petitioners. In both cases, the trustee is required, because of the past loss of the trust corpus, to use its own resources to take the place of the corpus or the lost income from the corpus____ It is in substance the award ... of “an accrued monetary liability””
1 later decision quote this exact passage · from the majority“[s]imply asking for injunctive relief and not damages does not clear the path for suit. The United States Supreme Court has recognized that the difference between retrospective and prospective relief will not in many instances be that between day and night.”
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.