Primary Care Investors, Seven, Inc. v. PHP Healthcare Corp.’s Empirical Analysis
986 F.2d 1208 · 1993
Citation profile
32 federal appellate · 3 district ·
How this case has been cited
Cited by 64 later decisions — most recently January 2024 · most notably Vicom, Inc. v. Harbridge Merchant Services, Inc. (1994), Handeen v. Lemaire (1997)
32 federal appellate · 3 district ·
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 Hj Inc v. Northwestern Bell Telephone Company · Lord Electric Co. v. United States · Alder v. United States · Dana Corp. v. Blue Cross & Blue Shield Mutual of Northern Ohio · Uni*Quality, Inc. v. Infotronx, Inc.
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“No Eighth Circuit case has set a minimum period of time over which the predicate acts must extend in order to be “substantial.” Other Circuits have consistently held that the requirement of continuity over a closed period is not met when the predicate acts extend less than a year. See, e.g., Uni*Quality, Inc. v. Infotronx, Inc., 974 F.2d 918, 922 (7th Cir.1992) (seven to eight months insufficient); Aldridge v. Lily-Tulip, Inc. Salary Retirement Plan Benefits Committee, 953 F.2d 587, 593 (11th Cir.) (six months to a year insufficient), rehearing denied, 961 F.2d 224 (11th Cir.1992); Hughes v. Consol-Pennsylvania Coal Co., 945 F.2d 594, 609-11 (3rd Cir.1991) (“twelve months is not a substantial period of time”), cert. denied, 504 U.S. 955 , 112 S.Ct. 2300 , 119 L.Ed.2d 224 (1992); American Eagle Credit Corp. v. Gaskins, 920 F.2d 352, 354-355 (6th Cir.1990) (six months insufficient). Many cases in which courts have found a “substantial period of time” have involved schemes extending for a number of years. See, e.g., Dana Corp. v. Blue Cross & Blue Shield Mut. of Ohio, 900 F.2d 882 , 887 (6th Cir.1990) (17 years); Fleet Credit Corp. v. Sion, 893 F.2d 441, 447 (1st Cir.1990) (four and a half years); Walk v. Baltimore and Ohio R.R., 890 F.2d 688, 690 (4th Cir.1989) (ten years). In this case, the activity lasted between ten and eleven months and, in light of the growing body of ease law that we have just reviewed, we deem this period insubstantial. Accordingly, plaintiffs did not pr”
2 later decisions quote this exact passage · from the majority“brief fails, however, to go beyond [a] cursory and summary statement”
2 later decisions quote this exact passage · from the majority“contentions ... with respect to the issues presented, and the reasons therefor, with citations, statutes and parts of the record relied on.”
1 later decision quote this exact passage · from the majoritye.g. Sidebottom v. Delo
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.