Rodgers v. Freborg’s Empirical Analysis

Citation profile

8 state decisions

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

1. ““Amendments by implication, like repeals by implication, are not favored and will not be upheld in doubtful cases. The legislature will not be held to have changed a law it did not have under consideration while enacting a later law, unless the terms of the subsequent act are so inconsistent with the provisions of the prior law that they cannot stand together.””

   2 later decisions quote this exact passage
   e.g. Kottsick v. Carlson · Birst v. Sanstead

2. ““Whenever a general provision in a statute shall be in conflict with a special provision in the same or in another statute, the two shall be construed, if possible, so that effect may be given to both provisions, but if the conflict between the two provisions is irreconcilable the special provision shall prevail and shall be construed as an exception to the general provision, unless the general provision shall be enacted later and it shall be the manifest legislative intent that such general provision shall prevail.” 3”

   1 later decision quote this exact passage
   e.g. Herman v. Magnuson

3. “"There must be a clear repugnancy between the provisions of the new law and the old statute to such an extent that a necessary implication arises that the legislature by enactment of the latter Act intended to repeal the former, and then only to the extent of its repugnancy." First American Bank & Trust Company v. Ellwein, 198 N.W.2d 84, 98 (1972).”

   1 later decision quote this exact passage
   e.g. City of Grafton v. Four G's, Inc.