Wood v. Baum’s Empirical Analysis
2008
Citation profile
6 federal appellate · 12 district · 20 state decisions
How this case has been cited
Cited by 88 later decisions — most recently February 2026 · most notably In Re Citigroup Inc. Shareholder Derivative Litigation (2009), In Re Amerco Derivative Litigation (2011)
6 federal appellate · 12 district · 20 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 Aronson v. Lewis · Brehm v. Eisner · Rales v. Blasband Ex Rel. Easco Hand Tools, Inc. · In Re Caremark International Inc. Derivative Litigation · Malpiede v. Townson
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 88 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] plaintiff must also plead particularized facts that demonstrate that the directors acted with scienter, i.e., that they had actual or constructive knowledge that their conduct was legally improper. Therefore, the issue before [the Court] is whether the [SAC] alleges particularized facts that, if proven, would show that ... the [Director Defendants knowingly engaged in fraudulent or illegal conduct or breached in bad faith the covenant of good faith and fair dealing.”
6 later decisions quote this exact passage“[A] derivative complaint must plead facts specific to each director, demonstrating that at least half of them could not have exercised disinterested business judgment in responding to a demand.”
6 later decisions quote this exact passage“`mere threat of personal liability ... is insufficient to challenge either the independence or disinterestedness of directors'”
3 later decisions quote this exact passage
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.