Thomas v. Freeman’s Empirical Analysis
1997
Citation profile
196 state decisions
How this case has been cited
Cited by 204 later decisions — most recently March 2026 · most notably Fletcher v. University Hospitals (2008), Summerville v. City of Forest Park (2010)
196 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 Maryhew v. Yova · Perotti v. Ferguson · Logsdon v. Nichols · Ohio Furniture Co. v. Mindala · Goolsby v. Anderson Concrete Corp.
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 204 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“operates as an adjudication upon the merits unless the court, in its order for dismissal, otherwise specifies.”
9 later decisions quote this exact passage““In an action commenced, or attempted to be commenced, if in due time a judgment for the plaintiff is reversed, or if the plaintiff fails otherwise than upon the merits, and the time limited for the commencement of such action at the date of reversal or failure has expired, the plaintiff, or, if he dies and the cause of action survives, his representatives may commence a new action within one year after such date.” (Emphasis added.)”
7 later decisions quote this exact passage“unequivocally establishes that the savings statute can be used only once to refile a case.”
6 later decisions 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.