Relfe v. Rundle’s Empirical Analysis
103 U.S. 222 · 1880
Citation profile
68 federal appellate · 20 district · 104 state decisions
How this case has been cited
Cited by 287 later decisions (17 by the Supreme Court) — most recently April 1980 · most notably Lion Bonding & Surety Co. v. Karatz (1923), Morris v. Jones (1947)
68 federal appellate · 20 district · 104 state decisions — followed in 26 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.
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 287 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““By tlie charter of this corporation, if a dissolution was decreed, its property passed by operation of law to the superintendent of the insurance department of the state, and he was charged with the duty of winding up its affairs. Every policy holder and creditor in Louisiana is charged with notice of this charter right which all interested in the affairs of the corporation can insist shall be regarded. The appellees, when they contracted with the Missouri corporation, impliedly agreed that, if the corporation was dissolved under the Missouri, laws, the superintendent of the insurance depnrlment of the state should represent the company in all suits instituted by them in winding up its affairs. Relfe therefore became by operation of law the successor of the corporation in the litigation,” etc.”
8 later decisions quote this exact passage · from the majority““Belfe is not an officer of the Missouri State Court, but the person designated by law to take the property of any dissolved life insurance corporation of that State, and hold and dispose of it in trust for the use and benefit of creditors, and other parties interested. The law which clothed him with this trust was, in legal effect, part of the charter of the Corporation. He was the statutory successor of the Corporation for the purpose of winding up its affairs. As such he represents the Corporation at all times and places in all matters connected with his trust. He is the trustee of an express trust, with all the rights which properly belong to such a position. He is an officer of the State, and as such represents the State in its sovereignty while performing its public duties connected with the winding up of the affairs of one of its insolvent and dissolved corporations. His authority does not come from the decree of the court, but from the statute. He appeared in Louisiana not by virtue of any appointment from the court, but as the statutory successor of a corporation which the court had in a legitimate way dissolved and put out of existence. He was, in fact, the Corporation itself for all the purposes of winding up its affairs. . . . By the charter of this Corporation, if a dissolution was decreed, its property passed by operation of law to the Superintendent of the Insurance Department of the State, and he was charged with the duty of winding up its affairs. Every polic”
4 later decisions quote this exact passage · from the majoritye.g. Hale v. Hardon · Duke v. Jenks“The superintendent of the insurance department of a state in which a corporation was created, who is made by operation of law the successor of the corporation, is entitled to appear in a suit in another state against the corporation and claim a removal of the case on the ground of citizenship.”
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.