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← 77 Haw. 446 - Lee v. Elbaum

Lee v. Elbaum’s Empirical Analysis

1995

Citation profile

21
cited by 21 later decisions
1
states following
June 2022
most recently cited

20 state decisions

How this case has been cited

Cited by 21 later decisions — most recently June 2022

20 state decisions

1501995200020102020decided

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 Ellis v. Crockett · International Brotherhood of Electrical Workers, Local 1357 v. Hawaiian Telephone Co. · Harkins v. Ikeda · Sherry Ex Rel. Sherry v. Asing · Frase v. Henry

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

  1. “[t]he general principles of construction which apply to statutes also apply to administrative rules. As in statutory construction, courts look first at an administrative rule’s language. If an administrative rule’s language is unambiguous, and its literal application is neither inconsistent with the policies of the statute the rule implements nor produces an absurd or unjust result, courts enforce the rule’s plain meaning. International Bhd. of Elec. Workers, Local 1357 v. Hawaiian Tel. Co., 68 Haw. 316, 323 , 713 P.2d 943, 950 (1986) (citations omitted). Moreover, an administrative agency’s interpretation of its own rules is entitled to “deference unless it is plainly erroneous or inconsistent with the underlying legislative purpose.” Id.”
    8 later decisions quote this exact passage
  2. “[ejffective cross-examination of an expert witness requires advance preparation. The lawyer even with the help of his own experts frequently cannot anticipate the particular approach his adversary’s expert wifi take[.]” 77 Hawai'i at 454, 887 P.2d at 664 (citation omitted). The defense implicitly acknowledged the applicability of this principle to criminal cases in a September 13, 1995 letter advising the DPA that”
    1 later decision quote this exact passage
  3. “Evidence of the habit of a person or of the routine practice of an organization, whether coiToborated or not and regardless of the presence of eyewitnesses, is relevant to prove that the conduct of the person or organization on a particular occasion was in conformity with the habit or routine practice.”
    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.