Doe v. Frank’s Empirical Analysis
951 F.2d 320 · 1992
Citation profile
21 federal appellate · 17 district · 19 state decisions
How this case has been cited
Cited by 110 later decisions — most recently January 2026 · most notably United States v. Microsoft Corp. (1995), Does Thru XXIII v. Advanced Textile Corporation (2000)
21 federal appellate · 17 district · 19 state decisions — followed in 12 states
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 Bonner v. City of Prichard · Atlantic Richfield Co. v. Newman Oil Co. · Levin v. Gulotta · Doe v. Stegall · Southern Methodist University Ass'n v. Wynne & Jaffe
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 110 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Lawsuits are public events. A plaintiff should be permitted to proceed anonymously only in those exceptional cases involving matters of a highly sensitive and personal nature, real danger or physical harm, or where the injury litigated against would be incurred as a result of the disclosure of the plaintiff’s identity. The risk that a plaintiff may suffer some personal embarrassment is not enough.” Doe v. Frank, 951 F.2d at 324 .”
10 later decisions quote this exact passage · from the majoritye.g. M.M. v. Zavaras · In re Sealed“(1) plaintiffs challenging governmental activity; (2) plaintiffs required to disclose information of the utmost intimacy; and (3) plaintiffs compelled to admit their intention to engage in illegal conduct, thereby risking criminal prosecution.”
7 later decisions quote this exact passage · from the majority“customary and constitutionally-embedded presumption of openness in judicial proceedings.”
7 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.