Shiflet v. Eller’s Empirical Analysis
1984
Citation profile
16 federal appellate · 122 state decisions
How this case has been cited
Cited by 162 later decisions — most recently November 2014 · most notably Washington Suburban Sanitary Commission v. Riverdale Heights Volunteer Fire Co. (1987), School Board v. United States Gypsum Co. (1987)
16 federal appellate · 122 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 First Virginia Bank-Colonial v. Baker · Smith v. Fenner · Duffy v. Hartsock · Bartlett v. Roberts Recapping, Inc. · Walke v. Dallas, Inc.
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 162 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“protected from retroactive application of statutes.”
6 later decisions quote this exact passage · from the majority“which are not necessarily synonymous with vested rights, [but] are included within that part of the law dealing with creation of duties, rights, and obligations, as opposed to procedural or remedial law, which prescribes methods of obtaining redress or enforcement of rights.”
4 later decisions quote this exact passage · from the majority“[T]he right to recover contribution “arises only when one tort-feasor has paid or settled a claim for which other wrongdoers are also liable,” ... while the cause of action for contribution arises at the time of the jointly negligent acts____ This cause of action is a substantive right manifested by the ability of one tort-feasor to seek contribution from another wrongdoer jointly liable and by the ability of a joint wrongdoer to defend successfully a suit by the plaintiff after the plaintiff has released another joint tort-feasor. Because the cause of action for contribution accruing to [the non-settling] joint tort-feasor[ ] arose at the time of the jointly negligent acts in [ ] 1977, it necessarily follows that the 1979 statute in question, which adversely affects that substantive right, cannot be applied retroactively to impair that right____ [W]e hold that the trial court correctly determined that issues affecting the substantive right of contribution are to be determined by the law which existed at the time of the tort giving rise to the cause of action for contribution ... and properly decided that Code § 8.01-35.1 affects substantive rights of joint tortfeasors, not merely the procedural aspects of their remedy.”
1 later decision 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.