Coppie Gouveia McCowen Gouveia’s Empirical Analysis
Citation profile
2 district ·
How this case has been cited
Cited by 43 later decisions — most recently April 2017 · most notably Johnson v. Ford Motor Credit Co. (In Re Johnson) (1985), Carlsen v. Internal Revenue Service (In Re Carlsen) (1986)
2 district ·
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 In the Matter of Unr Industries Inc et Als · Riddervold v. Saratoga Hospital · Grain Merchants of Indiana, Inc., Bankrupts, Mark L. France, Trustee v. Union Bank and Savings Company, Bellevue, Ohio · Cox v. General Electric Credit Corp. (In Re Cox) · Eggleston v. Third National Bank (In Re Eggleston)
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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he employers owed that portion of [the employees’] salaries directly to the garnishment plaintiffs and were liable to the plaintiffs for those amounts if the wages were not withheld pursuant to the court orders. True, the employers were not liable until the wages were actually earned, but once the court orders were entered the debtors were no longer legally entitled to 10% of their future salaries. Because the court orders legally transferred 10% of the debtors’ wages to the garnishment plaintiffs, there were no transfers at the time of the actual garnishments in question.”
5 later decisions quote this exact passage · from the majority“[A]fter a garnishment order providing for a continuing lien is entered in Indiana, a debtor will never acquire rights in the portion of his or her wages to be garnished in the future. Once a garnishment order has been entered by the court, the debtor’s rights in 10% of his or her future wages are irrevocably transferred to the garnishment plaintiff.”
5 later decisions quote this exact passage · from the majority“For the purposes of this section, a transfer is not made until the debtor has acquired rights in the property transferred.”
4 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.