Wyatt v. Cole’s Empirical Analysis
994 F.2d 1113 · 1993
Citation profile
11 federal appellate · 1 district · 7 state decisions
How this case has been cited
Cited by 44 later decisions (1 by the Supreme Court) — most recently March 2021 · most notably Jordan, Jordan v. Fox, Rothschild, O'Brien & Frankel (1994)
11 federal appellate · 1 district · 7 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 Harlow v. Fitzgerald · Anderson v. Creighton · Monroe v. Pape · Malley v. Briggs · Kentucky v. Graham
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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[P]rivate defendants should not be held liable under Sec. 1983 absent a showing of malice and evidence that they either knew or should have known of the statute's constitutional infirmity.”
5 later decisions quote this exact passage · from the concurrencee.g. Foust v. McNeill · Joe J. Jordan James E. Mitchell Jordan Mitchell, Inc. v. Fox, Rothschild, O'Brien & Frankel, Joe J. Jordan James E. Mitchell Jordan Mitchell, Inc., on Their Own Behalf and on Behalf of All Others Similarly Situated v. Arnold T. Berman Myron J. Berman John J. Petit, Jr., Prothonotary of the Court of Common Pleas of Philadelphia County, Joe J. Jordan James E. Mitchell Jordan Mitchell, Inc., at No. 92-1424, Arnold T. Berman and Myron J. Berman, at No. 92-1456“[i]t seems problematic to say that a defendant should be relieved of liability under some automatic rule of immunity if objective reliance upon a statute is reasonable but the defendant in fact had knowledge of its invalidhy. Because the burden of proof on this question is the plaintiff's, the question may be resolved on summary judgment if the plaintiff cannot come forward with facts from which bad faith can be inferred. But the question is a factual one and the plaintiff may rely on circumstantial rather than direct evidence to make his case. (Citation omitted.) The rule of course works in the reverse, for the existence of a statute thought valid ought to allow the defendant to argue that he acted in subjective good faith and is entitled to exoneration no matter what the objective test is.”
1 later decision quote this exact passage · from the concurrence“private defendants ... may be held liable for damages under § 1983 only if they failed to act in good faith in invoking the unconstitutional state procedures, that is, if they either knew or should have known that the statute upon which they relied was unconstitutional.”
1 later decision quote this exact passage · from the dissent
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.