Greenwood v. Freight Co.’s Empirical Analysis
105 U.S. 13 · 1881
Citation profile
15 federal appellate · 12 district · 78 state decisions
How this case has been cited
Cited by 240 later decisions (41 by the Supreme Court) — most recently January 2003 · most notably Ashwander v. Tennessee Valley Authority (1936), Omnia Commercial Co. v. United States (1923)
15 federal appellate · 12 district · 78 state decisions — followed in 27 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 Trustees of Dartmouth College v. Woodward · Fletcher v. Peck · Hawes v. Oakland · The West River Bridge Company v. Joseph Dix · Railroad Company v. Maine
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 240 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In short, whatever power is dependent solely upon the grant of the charter, and which could not he exercised hy unincorporated private persons under the general laws of the state, is abrogated by the repeal of the law which granted these special rights. “Personal and real property acquired by the corporation during its lawful existence, rights of contract, or ehoses in action so acquired, and which do' not in their nature depend upon the general powers conferred by the charter, are not destroyed by such a repeal ; and the courts may, if the Legislature does not provide some special remedy, enforce such rights by the means within their power. The rights of the shareholders of such a corporation, to their interest in its property, are not annihilated by such a repeal, and there must remain in the courts the pqwer to protect those rights.””
6 later decisions quote this exact passage · from the majority““One obvious effect is that it (the corporation) no longer exists. Its life is at an end. Whatever force the law may give to transactions into which the corporation entered, and which were authorized by the charter while in force, it can originate no new transactions dependent upon the power conferred by the charter. . . .. Personal and real.property acquired by the corporation during its lawful existence, rights of contract, or choses of action so acquired, and which do not in their nature depend upon the general powers conferred by the charter, are not destroyed by such a repeal. ... It results from this view that, whatever right remained in the Marginal Company to its rolling stock, its horses, its harness, its stables, the debts due it, and the funds on hand, if any, it no longer .had the right to run its cars through the streets, or any of the streets, of Boston. . . . Whether this action was oppressive or unjust, in view of the public good, or whether the legislature was governed by sufficient reason in .thus repeal ing the charter of one company and in chartering another, . is not, as we have seen, a judicial question in this case.””
2 later decisions quote this exact passage · from the majority““It is sufficient to say that this bill'presents so strong a case of the total destruction of the corporate existence, and of the annihilation of all corporate powers under the act of 1872, that we think complainant as a stockholder comes within the rule laid down in that opinion, and which authorizes a shareholder to maintain a suit to prevent such a disaster, where the corporation peremptorily refuses to move in the matter.””
2 later decisions 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.