Fields v. Evans’s Empirical Analysis
1985
Citation profile
11 state decisions
How this case has been cited
Cited by 11 later decisions — most recently October 2012
11 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 Mullane v. Central Hanover Bank & Trust Co. · Mennonite Board of Missions v. Adams · Schroeder v. City of New York · 125 Ind. App. 46 - Miladin v. Istrate, Admr. · City of Indianapolis v. Sherman
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Based on the words and effect of the statutes controlling tax sales and tax deeds, however; we conclude that the tax sale and the tax deed are separate events determining rights and interests in property and therefore require separate notices, as specified by statute. The tax sale creates a lien against the property that may ripen into full ownership at some later time by the issuance of a tax deed."”
2 later decisions quote this exact passage · from the dissent“"Even if we are to assume that no notice was required by statute, we would nevertheless be forced to conclude that, as applied here, constitutional standards of notice were not met." Id., p. 38, and "... we conclude that the tax sale and the tax deed are separate events determining the rights and interests in the property and therefore require separate notices, as specified by statute." Ibid., and "... 1.G. 6-1.1-25-1 provides that those with an interest in the property may redeem it at any time before a tax deed is issued. Given the untoward result of a failure to redeem, notice to interested parties of the right to redeem is required as an element of due process." Ibid., and, "... recent cases have required, at minimum, notice by mail to those whose interests appear in the public record. See eg., Mennonite Board of Missions v. Adams (1983), 462 U.S. 791 , 103 S.Ct. 2706 , 77 L.Ed.2d 1180 ." Id., p. 39.”
1 later decision quote this exact passage · from the dissente.g. Calhoun v. Jennings“The county auditor shall send a notice by certified mail to the former owner of real property not more than sixty (60) days nor less than thirty (30) days before a tax deed for the property is executed and delivered under this chapter. (Emphasis added.)”
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.