Runyon v. Paley’s Empirical Analysis
1992
Citation profile
2 federal appellate · 65 state decisions
How this case has been cited
Cited by 76 later decisions — most recently January 2026 · most notably McCrann v. Pinehurst, LLC (2013), Wise v. HARRINGTON GROVE COMMUNITY ASS'N (2003)
2 federal appellate · 65 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 Lane v. Scarborough · Tarvis v. Moran · Neponsit Property Owners' Ass'n v. Emigrant Industrial Savings Bank · Turner v. . Glenn · Washington National Arena Ltd. Partnership v. Comptroller of Treasury
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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the subject of the covenant touches and concerns the land, (2) there is privity of estate between the party enforcing the covenant and the party against whom the covenant is being enforced, and (3) the original covenanting parties intended the benefits and the burdens of the covenant to run with the land.”
4 later decisions quote this exact passage“create[] a personal obligation or right enforceable at law only between the original covenanting parties[.]”
3 later decisions quote this exact passage“most states require two types of privity: (1) privity of estate between the covenantor and covenantee at the time the covenant was created (“horizontal privity”), and (2) privity of estate between the covenanting parties and their successors in interest (“vertical privity”). . . . Vertical privity, which is ordinarily required to enforce a real covenant at law, requires a showing of succession in interest between the original covenanting parties and the current owners of the dominant and servient estates. . . . [T]o show horizontal privity, it is only necessary that a party seeking to enforce the covenant show that there was some “connection of interest” between the original covenanting parties[.]'”
2 later decisions 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.