Darnall v. State’s Empirical Analysis
1961
Citation profile
2 district · 74 state decisions
How this case has been cited
Cited by 78 later decisions — most recently February 2026 · most notably Hendrickson v. State (1964), Hurley v. State (1966)
2 district · 74 state decisions — followed in 10 states
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 Rose v. State of California · Bacich v. Board of Control · Archer v. City of Los Angeles · State v. Thelberg · Angelle v. State
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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Where a state or an agency thereof acting in a sovereign capacity takes or damages private property for public use without (formally) exercising the power of eminent domain, it cannot evade the constitutional provision which guarantees the right to compensation but will be obligated to pay the same as if it had proceeded under that power.” Darnall v. State, 1961, 79 S.D. 59 , 108 N.W.2d 201 .”
3 later decisions quote this exact passage“relocations of a highway, prohibitions against crossing it or against left and U túrns, the designation of one-way streets and other similar restrictions and regulations have been upheld as proper exercises of the police power of the state and not of the power of eminent domain. As such they are not compensable.”
2 later decisions quote this exact passage“The legislature shall direct by law in what manner and in what courts suits may be brought against the state.”
2 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.