Abreu v. Gilmer’s Empirical Analysis
1999
Citation profile
9 state decisions
How this case has been cited
Cited by 9 later decisions — most recently April 2025
9 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 Levine v. Remolif · Cha Venture v. Gc Wallace Cons. Eng. · Price v. Dunn · Jarstad ex rel. Jarstad v. National Farmers Union Property & Casualty Co. · Christy v. Carlisle
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[There is no objective, formulaic standard for determining what is, or is not, due diligence. The due diligence requirement is not quantifiable by reference to the number of service attempts or inquiries into public records. Instead,; due diligence is measured by the qualitative efforts of a specific plaintiff seeking to locate and serve a specific defendant As the Utah Supreme Court recogmzed The diligence to be pursued and shown is that which is reasonable under the circumstances and not all possible diligence which may be conceived. Nor is it that diligence which stops just short of the place where if it were continued might reasonably be expected to uncover an address ... of the person on whom service is sought.... Due diligence must be tailored to fit the cireamstances of each case. «It is that diligence which is appropriate to accomplish the end sought and which is reasonably calculated to do so.”
2 later decisions 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.