Jonnet v. State’s Empirical Analysis
1994
Citation profile
10 state decisions
How this case has been cited
Cited by 10 later decisions — most recently March 2016
10 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 Morrison v. Chan · Sharp v. House of Lloyd, Inc. · Seay v. Hall · Schwab v. Schlumberger Well Surveying Corp. · Coastal States Gas Producing Company v. Pate
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[The language of subsection (c)] makes perfect sense when applied to contractual debts undertaken by the corporation. In operation, it means that if a corporation contracts to pay a certain amount of money during the time that its corporate privileges are suspended, the officers and directors who either objected to or did not know about the incursion of the debt may not be held personally accountable to satisfy it. However, officers and directors who had knowledge of the incursion of a debt and failed to object to it may be personally liable for it. The language in subsection (c)(2) that qualifies the “knowledge” component means that a corporate officer or director cannot lay behind the log and be immune from personal accountability on the basis of ignorance if such ignorance is shown to be unreasonable. The exception, in effect, holds the decision-makers liable for debts which they exercised, or at least had the ability to exercise, some control over incurring.... Viewing the enactment from this perspective reveals that the legislature envisioned personal liability only for debts created or incurred through some sort of “affairs of the corporation” about which the director or officer in question had some knowledge and control. In referring to “the intention to create the debt,” the legislature can only have been speaking of the corporation’s intention. Thus, an interpretation allowing personal liability to be imposed for a debt “created” by a third party ..., without any inv”
1 later decision quote this exact passage · from the dissente.g. Williams v. Adams“[PJersonal liability is determined by the acts of Respondents in consenting to and approving the debts of the corporation where knowledge of their creation is shown to have come to them in the regular course of the business of the corporation. This is neither imputed knowledge nor “vicarious” liability as Respondents suggest; it is liability which results from and is attributable to the acts of Respondents. They had only to disapprove and disavow the debts to avoid personal liability; but having consented to and approved the debts, they became personally liable therefore.”
1 later decision quote this exact passage · from the dissente.g. Williams v. Adams“So far as we are able to find, the word “debt” as used in [section 171.255] has never been thought to include an obligation that is unliquidated. Indeed, it is difficult to see how such a meaning could be assigned the word if it is required to be construed strictly, that is to say, narrowly, literally, and technically.”
1 later decision quote this exact passage · from the concurrence
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.