Henderson v. DeRobertis’s Empirical Analysis
940 F.2d 1055 · 1991
Citation profile
39 federal appellate · 1 district · 2 state decisions
How this case has been cited
Cited by 67 later decisions — most recently May 2025 · most notably Murphy v. Walker (1995), Young v. Quinlan (1992)
39 federal appellate · 1 district · 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
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Harlow v. Fitzgerald · Anderson v. Creighton · Bell v. Wolfish · Wilson v. Seiter · Gregory Lumber Co. v. United States
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 67 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“exposed to temperatures below freezing for four days without affording them any protection beyond that usually provided when the heating system functioned properly”
2 later decisions quote this exact passage · from the majority“actual knowledge of impending harm, easily preventable, so that a conscious, culpable refusal to prevent harm could be inferred from [a] failure to prevent it,”
2 later decisions quote this exact passage · from the majority“In its judgment, the district court said it could not “find the right plaintiffs asserted under the facts of this ease to have been clearly established in 1982 to remove defendants’ qualified immunity.” Nevertheless, the district court, in its ruling, noted pre-1982 eases where appellate courts held that the constitution required prisoners to be provided with adequate heat and shelter. For example, the district court cited Lareau v. Manson, 651 F.2d 96 (2d Cir.1981) (prisoners are entitled to adequate shelter); Wright v. Rushen, 642 F.2d 1129 , 1132-33 (9th Cir.1981) (an institution has eighth amendment obligation to provide prisoners with adequate shelter or quarters); Ramos v. Lamm, 639 F.2d 559 , 568 (10th Cir.1980) (the state must provide reasonably adequate heat to inmates), cert. denied, 450 U.S. 1041 , 101 S.Ct. 1759 , 68 L.Ed.2d 239 (1981); Wolfish v. Levi, 573 F.2d 118 , 125 (2d Cir.1978) (the court said that “an institution’s obligation under the eighth amendment is at an end if it furnishes sentenced prisoners with adequate food, clothing, shelter, sanitation, medical care, and personal safety”), rev’d sub nom. Bell v. Wolfish, 441 U.S. 520 , 99 S.Ct. 1861 , 60 L.Ed.2d 447 (1979); Kirby v. Blackledge, 530 F.2d 583 , 587 (4th Cir.1976) (allegation of inadequate heating reaches the level of cruel and unusual punishment); and Bell v. Wolfish, 441 U.S. at 529 n. 11, 99 S.Ct. at 1869 n. 11. Plaintiffs cite additional eases in support of the same proposition. See Bono v.”
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.