Rhea v. Newman’s Empirical Analysis
1913
Citation profile
51 state decisions
How this case has been cited
Cited by 51 later decisions — most recently September 2016 · most notably Stolberg v. Caldwell (1978), State ex rel. Atlantic Coast Line Railroad v. Board of Equalizers (1922)
51 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 Norton v. Shelby County
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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The distinction here pointed out by the court as to the legal nature and effect of an appropriation is necessarily sound, for, when we .speak of one being indebted, we contemplate the state' of. his being under obligation to make payment, as of money or services, to another. “We do not mean to be understood as saying that an appropriation may not constitute a debt. It may be of such a character as to have all the .essential elements of a contract, and in such a case unquestionably it would be a. debt; but under the authorities quoted above, an appropriation which merely authorizes the payment of a gratuity, or is made in support of one of the state institutions, or to create or maintain a useful arm of the state government, or to defray the ordinary or current expenses of the state, does not constitute a debt such as is prohibited by section 49 of the constitution.””
1 later decision quote this exact passage · from the majoritye.g. Stanley v. Townsend““The general assembly may contract debts to meet casual deficits or failures in the revenue; but such debts, direct or contingent, singly or in the aggregate, shall not at any time exceed five hundred thousand dollars ($500,000.00), and the moneys axis ing from loans creating such debts shall be applied only to the purpose or purposes for which they were obtained, or to repay such debts: Provided, The general assembly may contract debts to repel invasion, suppress insurrection, or; if hostilities are threatened, provide for the public defense.””
1 later decision quote this exact passage · from the majority““But the fact that the money was not in the treasury when the warrants were presented did not affect their validity, since they will be paid by the treasurer when the money comes in, in the due course .of the revenues.””
1 later decision quote this exact passage · from the majoritye.g. Stanley v. Townsend
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.