Richardson v. Hardwick’s Empirical Analysis
106 U.S. 252 · 1882
Citation profile
56 federal appellate · 8 district · 58 state decisions
How this case has been cited
Cited by 161 later decisions (6 by the Supreme Court) — most recently November 2004 · most notably Shappirio v. Goldberg (1904), Helvering v. San Joaquin Fruit & Investment Co. (1936)
56 federal appellate · 8 district · 58 state decisions — followed in 22 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 Brown v. Spofford · Specht v. Howard · Forsythe v. Kimball · Samuel Sprigg v. The Bank of Mount Pleasant
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 161 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“. “The written contract gives him the privilege, or as counsel call it, an ‘option,’ to become equally interested in the lands by paying one-half the purchase money, etc., within two years after its date. The contract of itself did not vest him with any interest or estate in the lands. It merely pointed out the mode in which he might acquire interest, namely, by paying a certain sum of money before a certain time. He did not pay the money within the time limited by the contract. * * * It is clear from the terms of the contract that Richardson was not bound by it. ,He did not agree to purchase any share in the lands, or to pay Hardwick any money. The contract gave Hardwick no cause of action against Richardson. The latter was not bound to become interested in the lands, or to pay any money thereon, unless he chose to do so. In suits upon unilateral contracts, it is only where the defendant has had the benefit of the consideration for which he bargained that he can be held bound.””
5 later decisions quote this exact passage · from the majority““But evidence to establish this understanding is clearly inadmissible. In respect to this matter the contract is free from ambiguity. Its plain meaning is that Richardson was to make payment directly to Hard-wick, in money of one-half the amount paid by the latter on the lands. It is, therefore, not competent to show by parol that payment was to be made in some other way than that specified in the written instrument.””
2 later decisions quote this exact passage · from the majority““The plaintiff having failed to pay the money, or any part of it, within the time limited, the privilege accorded him by the contract was at an end, and all the rights under it ceased.””
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.