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← 351 Ark. 269 - Ivy v. Keith

Ivy v. Keith’s Empirical Analysis

2002

Citation profile

101
cited by 101 later decisions
1
states following
March 2026
most recently cited

101 state decisions

How this case has been cited

Cited by 101 later decisions — most recently March 2026 · most notably Omni Holding & Development Corp. v. 3D.S.A., Inc. (2004), Jones v. Arkansas Department of Human Services (2005)

101 state decisions

410200220102020decided

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 Cooter & Gell v. Hartmarx Corp. · Penfield Co of California v. Securities & Exchange Commission · In re Nevitt · Fitzhugh v. State · Green v. State

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

  1. “carry the keys of their prison in their own pockets.”
    7 later decisions quote this exact passage
  2. “(a) Every court of record shall have power to punish, as for criminal contempt, persons guilty of the following acts and no others: (1) Disorderly, contemptuous, or insolent behavior committed during the court's sitting, in its immediate view and presence, and directly tending to interrupt its proceedings or to impair the respect due to its authority; (2) Any breach of the peace, noise, or disturbance directly tending to interrupt its proceedings; (3) Willful disobedience of any process or order lawfully issued or made by it; (4) Resistance willfully offered by any person to the lawful order or process of the court; and (5) The contumacious and unlawful refusal of any person to be sworn as a witness and when so sworn a similar refusal to answer any legal and proper interrogatory. (b)(1) Punishment for contempt is a Class C misdemeanor. (2) A court shall always have power to imprison until its adjournment. (3) When any person is committed to prison for the nonpayment of any such fine, he or she shall be discharged at the expiration of thirty (30) days. (c) Contempts committed in the immediate view and presence of the court may be punished summarily. In other cases, the party charged shall be notified of the accusation and shall have a reasonable time to make his or her defense. (d)(1) Whenever any person is committed for a contempt under the provisions of this section, the substance of his or her offense shall be set forth in the order or warrant of commitment. (2) Nothing in ”
    2 later decisions quote this exact passage
  3. “[o]ur constitution and case law make it clear that the courts of this state have inherent power to punish a contemnor for contempts committed in the presence of the court or in disobedience of process. Ark. Const, art. 7, § 26. See also Johnson v. Johnson, 343 Ark. 186 , 33 S.W.3d 492 (2000); Carle v. Burnett, 311 Ark. 477 , 845 S.W.2d 7 (1993); Yarbrough v. Yarbrough, 295 Ark. 211 , 748 S.W.2d 128 (1988). This inherent power goes beyond the statutory authority provided by § 16-10-108. There is no question that willful disobedience of a valid order of a court is contemptuous behavior. Ark.Code Ann. § 16-10-108(a)(8) (Repl.1999). Before a person can be held in contempt for violating a court order, the order must be definite in its terms, clear as to what duties it imposes, and express in its commands. E.g., Lilly v. Earl, 299 Ark. 103 , 771 S.W.2d 277 (1989). We have observed in the past that contempt is a matter between the judge and the litigant, and not between the two opposing litigants. See Hickinbotham v. Williams, 228 Ark. 46 , 305 S.W.2d 841 (1957).”
    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.