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← 93 Haw. 142 - Lee v. Yano

Lee v. Yano’s Empirical Analysis

2000

Citation profile

5
cited by 5 later decisions
2
states following
October 2021
most recently cited

4 state decisions

How this case has been cited

Cited by 5 later decisions — most recently October 2021

4 state decisions

20200020102020decided

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 Amfac, Inc. v. Waikiki Beachcomber Investment Co. · United States v. Kirkpatrick · Roxas v. Marcos · F. H. McGraw & Co. v. Milcor Steel Co. · Brooks v. Minn

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

  1. “"[als a general rule, a third person who is secondarily liable on a debt, such as a guarantor, surety, or indorser, cannot control the application which either the debtor or the creditor makes of a payment, and neither the debtor nor the creditor need apply the payment in the manner most beneficial to such persons."”
    2 later decisions quote this exact passage · from the majority
  2. “(1) If neither the debtor nor the creditor has exercised his power with respect to the application of a payment as between two or more matured debts, the payment is applied to debts to which the creditor could have applied it with just regard to the interests of third persons, the debtor and the creditor. (2) In applying payments under the rule stated in Subsection (1), a payment is applied to the earliest matured debt and ratably among debts of the same maturity. ...”
    1 later decision quote this exact passage · from the majority
  3. “as the principal debtor. While a principal debtor promises to pay a specified amount, a guarantor promises to pay that amount only if it cannot be collected from the principal debtor. See Schweitzer v. Fishel, 13 Haw. 690, 693 (1901) (holding a guarantor and principal debtor were not”
    1 later decision quote this exact passage · from the majority

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.