Creach v. Angulo’s Empirical Analysis
1996
Citation profile
32 state decisions
How this case has been cited
Cited by 32 later decisions — most recently January 2024 · most notably Tritschler v. Allstate Insurance (2006), Creach v. Angulo (1997)
32 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 International Shoe Co. v. Washington · Hanson v. Denckla · McGee v. International Life Insurance · Town of Chino Valley v. City of Prescott · Cockerham v. Zikratch
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“To justify the reversal of a case, there must not only be error, but the error must have been prejudicial to the substantial rights of the party. State v. Whitman, 91 Ariz. 120, 127 , 370 P.2d 273, 278 (1962); see also Ariz. Const, art. 6, § 27 (prohibiting reversal of a cause for technical error in pleading or proceedings). Furthermore, prejudice is not presumed but must appear from the record. Whitman, 91 Ariz. at 127 , 370 P.2d at 278 . Otherwise, the error is deemed harmless. Id. Rule 61 of the Arizona Rules of Civil Procedure defines harmless error as follows: “No error or defect ... in anything done or omitted by the court or by any of the parties is ground for ... vacating, modifying or otherwise disturbing a judgment or order, unless refusal to take such action appears to the court inconsistent with substantial justice. The court at every stage of the proceeding must disregard any error or defect in the proceeding which does not affect the substantial rights of the parties.””
1 later decision quote this exact passagee.g. Creach v. Angulo“[W]e believe the affidavit was intended to provide assurance to the trial court that its assertion of personal jurisdiction was constitutionally permissible. Such assurance was especially important in the default judgment context where the defendant has not answered the complaint and the record may not contain information necessary to determining the appropriateness of long arm jurisdiction. Thus, the affidavit requirement insures that the trial court receives this information before entering a default judgment.”
1 later decision quote this exact passagee.g. Creach v. Angulo“[T]he issue before the Cockerham court was whether the technical violation prevented establishment of personal jurisdiction, not whether it would otherwise be reversible error____ It is readily apparent that the Cockerham court’s statement regarding reversible error was hypothetical and not necessary to its holding.”
1 later decision quote this exact passagee.g. Creach v. Angulo
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.