Peters v. Weatherwax’s Empirical Analysis
1987
Citation profile
35 state decisions
How this case has been cited
Cited by 35 later decisions — most recently March 2025 · most notably Hawaii Ventures, LLC v. Otaka, Inc. (2007), State Farm Fire & Casualty Co. v. Pacific Rent-All, Inc. (1999)
35 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 Putnam v. Commissioner · Late Corporation of the Church of Jesus Christ of Latter-Day Saints v. United States · Gilbert v. United States · In re Dole · Stop H-3 Ass'n v. State of Hawaii Department of Transportation
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Subrogation is a venerable creature of equity jurisprudence, “so administered as to secure real and essential justice without regard to form[.]” H. Sheldon, The Law of Subrogation § 1, at 2 (1882) (footnote omitted). “It is broad enough to include' every instance in which one party pays a debt for which another is primarily answerable, and which, equity and good conscience, should have been discharged by the latter[.]” Id. (footnote omitted). It “is defined by Sheldon to be ‘the substitution of another person in the place of a creditor, so that the person in whose favor it is exercised succeeds to the rights of the creditor in relation to the debt.’ ” Kapena v. Kaleleonalani, 6 Haw. 579, 583 (1885). When subrogation occurs, “[t]he substitute is put in all respects in the place of the party to whose rights he is subrogated.” Id. In effect, he “steps into the shoes” of the party. See Putnam v. Commissioner, 352 U.S. 82, 85 , 77 S.Ct. 175, 176 , 1 L.Ed.2d 144 (1956); A. Windt, Insurance Claims and Disputes § 10.05, at 409 (1982); Black’s Law Dictionary 1279 (5th ed.1979). [[Image here]] ... Furthermore, “[although, as between debtor and creditor, the debt may be extinguished, yet, as between the person who has paid the debt and the other parties, the debt is kept alive [by the doctrine of subrogation], so far as may be necessary to preserve the securities.” H. Sheldon, supra, § 11, at 10 (footnote omitted). When “the legislature enacts into statute law a common law concept, ... ”
4 later decisions quote this exact passage · from the majority“the substitution of another person in the place of a creditor, so that the person in whose favor it is exercised succeeds to the rights of the creditor in relation to the debt. When subrogation occurs, the substitute is put in all respects in the place of the party whose rights [are] subrogated. In effect, [the substitute] steps into the shoes of the [creditor].”
3 later decisions quote this exact passage · from the majority“[w]hen the legislature enacts into statute a common law concept, ... that is a clue that the courts are to interpret and apply the statute with the freedom with which they would construe and apply a common law principle.”
2 later decisions quote this exact passage · from the majority
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.