Christian Union v. Yount’s Empirical Analysis
101 U.S. 352 · 1879
Citation profile
2 federal appellate · 1 district · 37 state decisions
How this case has been cited
Cited by 82 later decisions (16 by the Supreme Court) — most recently February 1954 · most notably Julian v. Central Trust Co. (1904), Dolbear v. American Bell Telephone Co. (1888)
2 federal appellate · 1 district · 37 state decisions — followed in 20 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 Cowell v. Springs Co. · Runyan v. Lessee of Coster · Carroll v. City of East St. Louis
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In harmony with the general law of comity obtaining among the states composing the Union, the presumption should be indulged that a corporation of one state, not forbidden by the law of its being, may exercise within any other state the general powers conferred by its own charter, unless it is prohibited from so doing, either in the direct enactments of the latter state, or by its public policy to be deduced from the general course of legislation, or from the settled adjudications of its highest court. There was here no such direct legislation during or prior to the year 1870, nor can the existence of such a public policy be inferred from the general course of legislation or judicial decisions in Illinois up to and including that year, in relation to religious, benevolent, charitable, or missionary societies created in other states.””
3 later decisions quote this exact passage · from the majority““For, besides the aclmiitcd Incapacity of a corporation of one state to exorcise its powers in another state, except with the assent or permission, express or implied, of tlie latter, it is a principle ‘as inviolable as it is fundamental and conservative that the right to hold land and the mode of acquiring title to land must, depend altogether on the local law of the territorial sovereign,’ • in connection with which are cited Rumyan v. Coster’s Lessee, 14 Pet. 122 , and Lathrop v. Bank, 8 Dana. 114 .”
2 later decisions quote this exact passage · from the majority““The answer to this position is found in the genera] comity which, in the absence of positive direction- to the contrary, obtains through the states and territories of the United States, by which corporations created in one state or territory are permitted to carry on any lawful business in another state or territory, and to acquire, hold, and transfer property there equally as individuals. If the policy of the state or territory does not permit the business of the foreign corporation in its limits or allow a corporation to acquire or hold real property, it must be expressed in some affirmative way. It cannot be inferred from the fact that its Legislature lias made no provision for the formation of similar corporations or allows corporations to be formed only by general law. Telegraph companies did business in several states before their Legislatures had created or authorized the creation of similar corporations; and numerous corporations -existing by special charter in one state are now engaged, without question, in business in states where the creation of corporations by special enactment is forbidden.””
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.