Northrup v. Hayward’s Empirical Analysis
1907
Citation profile
1 federal appellate · 14 state decisions
How this case has been cited
Cited by 15 later decisions — most recently October 2008
1 federal appellate · 14 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 Porter, Taylor & Co. v. Hanson · Cones v. Brooks · Boogren v. St. Paul City Railway Co. · Young v. Dearborn · Braden v. Ward
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Attorney’s liens are divided into two classes, ‘possessory’ and ‘charging.’ The first exists at common law, and extends to all property in the possession of the attorney with respect to which he renders services to the owner. The lien is divested, as in other eases of similar liens, upon the surrender of possession of the property to the owner. The other class, the ‘charging’ lien, is a statutory creation, and was unknown to the common law. It was created by subdivisions 3 and 5, above set out, and extends to all money or property of the client, including judgments, with reference to which the attorney’s services were rendered, and is perfected when notice thereof is given the debtor. Prior to the adoption of the Revised Laws of 1905, this lien did not extend to the cause of action, but only to judgments recovered or money paid, or agreed to be paid as a result of the attorney’s services. Boogren v. St. Paul City Ry. Co., 97 Minn. 51 , 106 N. W. 104 , 3 L. R. A. (N. S.) 379 , 114 Am. St. Rep. 691 .The provisions of subdivision 3, giying an attorney a lien upon the cause of action of his client from the time of the service of summons, first became the law of this state by the adoption of the Revised Laws of 1905; but, unlike subdivision 5, no notice of the attorney’s claim is required to be given the opposite party.””
1 later decision quote this exact passagee.g. Byram v. Miner““Upon the cause of action from the time of the service of the summons therein.””
1 later decision quote this exact passagee.g. Akers v. Akers
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.