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← 122 Haw. 402 - Everson v. State

Everson v. State’s Empirical Analysis

2010

Citation profile

5
cited by 5 later decisions
3
states following
January 2025
most recently cited

5 state decisions

Relationships

Relies on Camara v. Agsalud · Dole Hawaii Division-Castle & Cooke, Inc. v. Ramil · State v. Kahlbaun · Kahoohanohano v. State · Pray v. JUDICIAL SELECTION COM'N

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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Membership in any employees' retirement system of the State or any political subdivision thereof shall be a contractual relationship, the accrued benefits of which shall not be diminished or impaired.”
    3 later decisions quote this exact passage · from the majority
  2. “As we observed in Kaho'ohanohano, the framers of article XVI, section 2 intended to provide the legislature with flexibility to make changes to the system so long as the changes neither diminished nor impaired a member’s accrued benefits. Accordingly, although article XVI, section 2 provides protection for any additional benefits that the legislature may decide to provide to state and county government employees as members of an ERS, consistent with the framers’ intent, the legislature may also reduce benefits as to persons already in the system in so far as their future services were concerned, but it could not, however, reduce the benefits attributable to past services.”
    2 later decisions quote this exact passage · from the majority
  3. “[A]rticle XVI, section 2 was intended in part to provide the legislature with flexibility to make future changes to the retirement system, which included changing the benefits that are provided to members of an ERS, as long as the changes did not reduce an employee’s benefits attributable to past services. There is also nothing to suggest that any additional benefits, once “accrued,” cannot be provided protection from diminishment or impairment pursuant to article XVI, section 2 if the government desires to maintain the system in good faith with the employees of the government.”
    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.