In the Matter of James Towers, Debtor-Appellant. State of Illinois’s Empirical Analysis
1999
Citation profile
9 federal appellate · 1 district ·
How this case has been cited
Cited by 47 later decisions — most recently February 2022 · most notably Rashid v. Powel (2000), United States v. Bach (1999)
9 federal appellate · 1 district ·
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 Pierce v. Underwood · Kelly v. Robinson · Pennsylvania Department of Public Welfare v. Davenport · Plaut v. Spendthrift Farm, Inc. · In the Matter of James Michael Zarzynski and Kathryn Kleist Zarzynskis
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 47 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“payable to and for the benefit of a governmental unit”
6 later decisions quote this exact passage · from the majoritye.g. City of Chi. v. Spielman (In re Spielman) · In Re Jason Derek Troff, Debtor, Jason Derek Troff v. State of Utah, Richard Ellis, in His Official Capacity as Executive Director of the Utah Department of Administrative Services and David Johnson Iii, in His Official Capacity as Interim Director of the Office of State Debt Collection“Federal criminal restitution orders and civil restitution orders share one important distinction from Kelly — neither implicates the federal court's longstanding `reluctan[ce] to interpret federal bankruptcy statutes to remit state criminal judgements.'”
3 later decisions quote this exact passage · from the majority“Deterrence of fraud is a benefit to all of the state’s citizens. If restitution adds to the punch of the criminal law, then so much the better. Some language in Kelly suggests this possibility. But the context in which “benefit” appears — • “payable to and for the benefit of a governmental unit” — implies that the “benefit” in question is the benefit of the money that is “payable to” the governmental unit. In Kelly the government received and kept the money; not so here. Citizenry at large may get the benefit of deterrence, but neither the people of Illinois nor any governmental unit receives a financial benefit from the restitution that Towers has been directed to pay, and the “governmental unit” does not receive any benefit from general deterrence either.”
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.