Kolton v. Frerichs’s Empirical Analysis

Citation profile

2 federal appellate · 1 state decisions

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

1. “must try to obtain compensation under state law before litigating a takings suit.”

   2 later decisions quote this exact passage · from the majority
   e.g. Squires-Cannon v. Forest Pres. Dist. of Cook Cnty. · Meryl Squires-Cannon v. Forest Preserve District of C

2. “takings claim ... accrues only when the government refuses to pay.”

   2 later decisions quote this exact passage · from the majority
   e.g. Squires-Cannon v. Forest Pres. Dist. of Cook Cnty. · Meryl Squires-Cannon v. Forest Preserve District of C

3. “The Supreme Court has held that the Takings Clause protects the time value of money just as much as it does money itself. Brown v. Legal Foundation of Washington , 538 U.S. 216 , 235 [ 123 S.Ct. 1406 , 155 L.Ed.2d 376 ] (2003) ; Phillips v. Washington Legal Foundation , 524 U.S. 156 , 165-72 [ 118 S.Ct. 1925 , 141 L.Ed.2d 174 ] (1998) ; Webb's Fabulous Pharmacies, Inc. v. Beckwith , 449 U.S. 155 , 162-65 [ 101 S.Ct. 446 , 66 L.Ed.2d 358 ] (1980). In Cerajeski v. Zoeller , 735 F.3d 577 (7th Cir. 2013), we applied these precedents to an Indiana statute like the Illinois statute in this case. We held that a state may not take custody of property and retain income that the property earns. A state may charge a bookkeeping fee, which for small accounts may exceed the property's time value, but must allow the owner the benefit of the property's earnings, however large or small they turn out to be. Id. at 578-80 .”

   1 later decision quote this exact passage · from the majority
   e.g. Goldberg v. Frerichs