Commonwealth v. Neiman’s Empirical Analysis

Citation profile

79 state decisions

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

1. “In conducting our review, we are guided by the principle that acts passed by the General Assembly are strongly presumed to be constitutional, including the manner in which they were passed. Thus, a statute will not be found unconstitutional unless it clearly, palpably, and plainly violates the Constitution. If there is any doubt as to whether a challenger has met this high burden, then we will resolve that doubt in favor of the statute’s constitutionality.”

   5 later decisions quote this exact passage
   e.g. 2017 Pa. Super. 162 - Commonwealth v. Fortson · Washington, Aplts. v. Dept. of Pub. Welfare

2. ““The first involved the insertion into a single bill of a number of distinct and independent subjects of legislation in order to deliberately hide the real purpose of the bill. The second was the practice of “logrolling” which involves embracing in one bill several distinct matters, none of which could singly obtain the assent of the legislature, and procuring its passage by combining the minorities who favored the individual matters to form a majority that would adopt them all.””

   4 later decisions quote this exact passage
   e.g. Phantom Fireworks Showrooms, LLC v. Tom Wolf, Governor of the Comwlth of PA · Leach v. Commonwealth

3. “. In determining ‘germaneness,’ our Court has acknowledged that, some degree of deference to the General Assembly’s prerogative to amend legislation is required, due to the normal fluidity inherent in the legislative process, and, thus, we have deemed it is appropriate for a reviewing court to hypothesize a .‘reasonably broad topic’ which would unify the various' provisions of a final bill as enacted. City of Philadelphia, [ 838 A.2d at 588 ]. However, our Court has also stressed-the ‘reasonable’ aspect of any proposed hypothetical unifying topic-, in- recognition of the fact that Article III, Section 3 would be rendered nugatory if such -hypothetical topics were too expansive. PAGE, [ 877 A.2d at 395 ]. We observed that, ‘no two subjects are so wide apart that they may not be brought into a common focus, if the point of .view be carried back far enough.’ . Id. (quoting Payne v. Sch. Dist. of Coudersport, [ 31 A. 1072 (Pa.1895))]. Consequently, in determining whether a proposed unifying subject is sufficiently narrow so as to pass muster under Article III, Section 3, our Court must examine the various subjects contained within a legislative enactment and determine whether they have a nexus to a common purpose. Stated another way, our task is to ascertain whether the various components of the enactment are part of ‘a unifying scheme to accomplish a single purpose.’ City of Philadelphia, [ 838 A.2d at 589 ] (citing Payne). In this regard, the mere fact that a piece of legislati”

   3 later decisions quote this exact passage
   e.g. Washington, Aplts. v. Dept. of Pub. Welfare · Leach v. Commonwealth