In Re Lewkowitz’s Empirical Analysis

Citation profile

20 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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““Every Act shall embrace but one subject and matters properly connected therewith, which subject shall be expressed in the title; but if any subject shall be embraced in an Act which shall not be expressed in the title, such Act shall be void only as to so much thereof as shall not be embraced in the title.””

   2 later decisions quote this exact passage
   e.g. In Re Twenty-One Slot MacHines, Etc. · General Electric Co. v. Telco Supply, Inc.

2. “The purpose of constitutional provisions such as ours, adopted in most states of the Union, is to prevent surprise and the evils of omnibus bills and surreptitious and hodge-podge legislation that were frequent in legislation prior to their adoption. [Citation omitted.] The question of the sufficiency of title: ‘ * * * is not one of intent on the part of the lawmakers in phrasing the title, but of its significance and meaning to those who might read it at that stage of its history when it was only a bill going through the process of its enactment into law.’”

   1 later decision quote this exact passage
   e.g. Allen v. Girard

3. “That any provision of the act directly or indirectly relating to the subject expressed in the title and having a natural connection therewith, and not foreign thereto, should be held to be embraced in it.”

   1 later decision quote this exact passage
   e.g. In Re Lewkowitz