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← 2008 ND 201 - Colombe v. Carlson

Colombe v. Carlson’s Empirical Analysis

2008

Citation profile

2
cited by 2 later decisions
2
states following
February 2012
most recently cited

2 state decisions

Relationships

Relies on Ortega-Rodriguez v. United States · Degen v. United States · John Walsh Jacqueline Walsh and Martha Miller Intervenor John Walsh Jacqueline Walsh and Martha Miller Intervenor · Empire Blue Cross and Blue Shield v. Finkelstein Kcg G · Stern v. United States

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

  1. ““First, in order to dismiss an appellant’s claim due to his or her fugitive status, a connection must exist between the litigant’s fugitive status and the litigant’s appeal.” Moscona, 649 S.E.2d at 198 (citing Ortega-Rodriguez [v. United States], 507 U.S. [284,] 249 [ 113 S.Ct. 1199 , 122 L.Ed.2d 581 (1998) ]). “Second, before implementing such, a severe sanction, a court must ask ‘whether an alternative short of dismissal will render enforcement of the underlying judgment certain and remove the risk of prejudice to the fugitive’s adversary.’” Id. (quoting Matsumoto v. Matsumoto[, 171 N. J. 110] 792 A.2d 1222, 1233 (N.J.2002)). Third, the policy concerns underlying the fugitive dismissal rule must be present. Id.; see also Degen [v. United States], 517 U.S. [820,] 824-25 [ 116 S.Ct. 1777 , 135 L.Ed.2d 102 (1996) ] (explaining that courts employ the fugitive dismissal rule to encourage enforcement of court orders, discourage the use of judicial resources only when the court rules in the fugitive’s favor, avoid prejudice to the non-fugitive party, discourage flights from justice, and promote the efficient, dignified operation of the courts).”
    1 later decision quote this exact passage
  2. “conclude[d] that the fugitive dismissal rule is applicable to civil cases and the facts of this case merit such a harsh result.”
    1 later decision quote this exact passage
  3. “recognize[d] that the fugitive dismissal rule should be invoked with great caution and restraint,”
    1 later decision 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.