Millersville Annexation Case’s Empirical Analysis
1972
Citation profile
27 state decisions
How this case has been cited
Cited by 27 later decisions — most recently September 1992 · most notably Commonwealth v. Kates (1973), 266 Pa. Super. 276 - Commonwealth Ex Rel. Platt v. Platt (1979)
27 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 Jenner Township Annexation Case · Millersville Annexation Case · 218 Pa. Super. 205 - Phoenixville Borough Annexation Case · In re Slatington Borough Ordinance
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 27 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“On the question of annexation, the Borough Code and the Second Class Township Code are unquestionably ‘in pari materia’, since they relate to the identical things — annexation by a borough of land in‘a second class township. Thus, the possibility of construing them as one law must be pursued. Again the Statutory Construction Act provides a solution. Section 563 [now 1 Pa.C.S. § 1933] states that a particular or special provision controls a general provision in the same or another law. If this is so, then it follows that when two statutes deal with the same things, a particular provision in one will control when the other statute is silent as to that matter. Thus, the particular provision in the Second Class Township Code relating to the number of freeholds to be counted in a tenancy by entireties controls and interprets the silence of the Borough Code on that matter.”
1 later decision quote this exact passage“Reliance on Jenner Township is misplaced. That case was limited to a decision that this court should refuse to attempt to consolidate the procedures set forth in the two statutes into a single annexation procedure. Here we are not reading the two statutes in pari materia procedurally. Rather, following the precepts of the Statutory Construction Act that the legislature is to be presumed rational, i.e., not intending unreasonable results, we are making a substantive determination that the legislature had to intend that “freeholders ’ ’ must be defined in the same way under both statutes. (Emphasis in original.) (Footnote omitted.)”
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.