St. Clair v. Cox’s Empirical Analysis
106 U.S. 350 · 1882
Citation profile
101 federal appellate · 92 district · 218 state decisions
How this case has been cited
Cited by 649 later decisions (63 by the Supreme Court) — most recently June 2023 · most notably International Shoe Co. v. Washington (1945), Perkins v. Benguet Consolidated Mining Co. (1952)
101 federal appellate · 92 district · 218 state decisions — followed in 43 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 Pennoyer v. Neff · Paul v. Virginia · Lafayette Insurance v. French · Libbey v. Hodgdon, Principal, & Portland Stage Co.
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 649 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ . . . It is sufficient to observe that we are of opinion that when, service is made within the state upon an agent of a foreign corporation, it is essentrial, in order to support the jurisdiction of .the court to render a personal judgment, that it should appear somewhere in the record—either in the application for the writ, or accompanying its service, or in the pleadings or the finding of the court—that the cor poration was engaged in business in the state. The transaction-of business by the corporation in the state, general or special, appearing, a certificate of service by the proper officer on a person who is its agent there-would, in our opinion, be sufficient prima facie evidence that the agent' represented the company in the business. It would then be open, when the record is offered as evidence-in another state, .to show that the agent stood in no representative character to the company, thát his.duties,were limited to those of a subordinate, employe, or to a particular transaction, or that, his .agency had ceased when the matter in suit arose.””
12 later decisions quote this exact passage · from the majority“[a] corporation of one state cannot do business in another state without the latter’s consent, express or implied,-and that consent may be accompanied with such conditions as it may think proper to impose.... The state may, therefore, impose as a condition upon which a foreign corporation shall be permitted to do business within her limits, that it shall stipulate that in any litigation arising out of its transactions in the state, it will accept as sufficient the service of process on its agents or persons specially designated, and the condition would be eminently fit and just.”
11 later decisions quote this exact passage · from the majority““According to the view thus expressed by the Supreme Court of Michigan, service upon an agent of a foreign corporation will not be deemed sufficient unless he represents the corporation in the state. This representation implies that the corporation does business or has business in the state for the transaction of which it sends or appoints an. agent there.””
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.