Laney v. Jefferson County’s Empirical Analysis
1947
Citation profile
2 district · 40 state decisions
How this case has been cited
Cited by 42 later decisions — most recently October 2006 · most notably Hutchinson v. Board of Trustees of University of Alabama (1971), Morgan County Commission v. Powell (1974)
2 district · 40 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 Hollenbeck v. County of Winnebago · Norton v. Lusk · Tucker v. Mobile Infirmary Ass'n · Askew v. Hale County · Williams v. City of Birmingham
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““While each count alleged that Jefferson County operated the Jefferson Hospital as a proprietary institution, such allegation would not be admitted if the county did not possess the legal authority so to do. A county is a ‘governmental auxiliary or agency possessing no power and subjected to no duty not originating from the statute creating it.’ Askew v. Hale County, 54 Ala. 639 , 25 Am.Rep. 730 . The question of whether the county is operating a proprietary institution is controlled by statutes which authorize it. Therefore the demurrer does not admit that the county was so engaged for that is a conclusion of law which a demurrer does not admit. . . . “But when the operation in question is proprietary in its character, and as such authorized by lazv, it is liable to suit for torts committed by its agents in the exercise of their duties as such. [Citations Omitted].” (Emphasis Supplied)”
1 later decision quote this exact passage““The fact that the county required or received pay, from such of the patients in the hospital as were able to pay, cannot serve to destroy the charitable character or purposes of the hospital, nor convert it into a proprietory institution. It still remained a charitable hospital, operated as a governmental institution. * * * ””
1 later decision quote this exact passage““ * * * The nature of the public business is not controlled by' the fact that a charge was made. Williams v. City of Birmingham, 219 Ala. 19 , 121 So. 14 .””
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.