Pate v. United States’s Empirical Analysis
982 F.2d 457 · 1993
Citation profile
19 federal appellate · 3 district · 1 state decisions
Relationships
Applies 26 U.S.C. § 7430
Relies on Pierce v. Underwood · Vandygriff v. Phillips · Hannahville Indian Community v. United States · Sisson v. Ruby · Sisson v. Ruby
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In determining whether the position of the United States was 'substantially justified,' the district court must look at all facts and circumstances as well as the legal precedents relating to the case, bearing in mind the applicant bears the burden of proof.”
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.