I don’t think it should count for another reason, namely that judge-made law is often referred to by the name of the case or the abbreviated name. Miranda, Roncarelli, Brown, Roe, etc. are all reasonably well-known among the public and certainly among the legal community.
Two cents: I think the practice of naming statutes after people is tacky, tacky, tacky. Tacky like naming your child Jade, McKenna, or Johnathon. Tacky like velvet clown paintings. Tacky like those lawn ornaments of a kid with his pants around his ankles pissing. Tacky, tacky, tacky, tacky, tacky.