State Ex Rel. Helman v. Gallegos’s Empirical Analysis
1994
Citation profile
8 district · 397 state decisions
How this case has been cited
Cited by 409 later decisions — most recently October 2024 · most notably State v. Smith (2004), State v. Rivera (2003)
8 district · 397 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 Youngstown Sheet & Tube Co. v. Sawyer · Michigan v. Ohio · 117 Wis. 2d 529 - Ball v. District No. 4, Area Board · 24 Cal. 3d 514 - People v. Tanner · Guiseppi v. Walling
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 409 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[C]ourts must exercise caution in applying the plain meaning rule. Its beguiling simplicity may mask a host of reasons why a statute, apparently clear and unambiguous on its face, may for one reason or another give rise to legitimate ... differences of opinion concerning the statute’s meaning. In such a case, it can rarely be said that the legislation is indeed free from all ambiguity and is crystal clear in its meaning. While ... one part of the statute may appear absolutely clear and certain to the point of mathematical precision, lurking in another part of the enactment, or even in the same section, or in the history and background of the legislation, or in an apparent conflict between the statutory wording and the overall legislative intent, there may be one or more provisions giving rise to genuine uncertainty as to what the legislature was trying to accomplish. In such a case, it is part of the essence of judicial responsibility to search for and effectuate the legislative intent — the purpose or object — underlying the statute. See Perea [v. Baca], 94 N.M. [624,] 627, 614 P.2d [541,] 544 [ (1980) ] (courts are permitted to interpret by looking to legislative intent if there is any doubt as to the meaning of the words) (emphasis added); State v. Herrera, 86 N.M. 224, 225-26 , 522 P.2d 76, 77-78 (1974) (statute construed based on perceived legislative object and purpose, rather than on literal language). ...”
12 later decisions quote this exact passage“a statute, apparently clear and unambiguous on its face, may for one reason or another give rise to legitimate (i.e., nonfrivolous) differences of opinion concerning the statute's meaning.”
6 later decisions quote this exact passage“conform to the obvious intent of the [L]egislature, or to prevent its being absurd.”
6 later decisions quote this exact passage
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.