Bess v. L Bess’s Empirical Analysis
Citation profile
4 federal appellate · 5 district · 4 state decisions
How this case has been cited
Cited by 27 later decisions — most recently June 2020 · most notably Steve Jackson Games Incorporated v. United States Secret Service (1994), Fearnow v. Chesapeake & Potomac Telephone Co. (1995)
4 federal appellate · 5 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
Relies on Hensley v. Eckerhart · Bradley v. School Board of City of Richmond · Bowen v. Georgetown University Hospital · Johnson v. Georgia Highway Express, Inc. · Pennsylvania v. Delaware Valley Citizens' Council for Clean Air
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(2) In any other action under this section, the court may assess as damages ... (B) statutory damages of whichever is greater of $100 a day for each day of violation or $10,000....”
3 later decisions quote this exact passage · from the majority“a wanton, reckless or malicious violation.”
2 later decisions quote this exact passage · from the majority“[Plaintiff] raises one meritorious claim with respect to the number of violations. The record reveals that on July 24,1985, during the Bess’ divorce proceeding, [defendant] recited facts obtained from the intercepted conversations in an attempt to establish marital misconduct by [plaintiff]. This use of the intercepted contents represents additional prohibited conduct in violation of 18 U.S.C. § 2511 . Cf. Rodgers v. Wood, 910 F.2d 444 , 446, 449 n. 3 (7th Cir.1990) (plaintiffs sought damages based on disclosure of intercepted conversations). We therefore determine that [plaintiff] is entitled to an additional $100 in statutory damages. 1”
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.