Hart v. Sansom’s Empirical Analysis
110 U.S. 151 · 1884
Citation profile
43 federal appellate · 8 district · 103 state decisions
How this case has been cited
Cited by 234 later decisions (24 by the Supreme Court) — most recently December 2018 · most notably Baldwin v. Ionwa State Traveling Men's Ass'n (1931), Estin v. Estin (1948)
43 federal appellate · 8 district · 103 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 Pennoyer v. Neff · Massie v. Watts · John Orton v. George Smith · Ager v. Murray
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 234 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * * * a court of equity acts in personam, by compelling a deed to be executed or canceled by or in behalf of the party. It has no inherent power, by the mere force of its decree, to annul a deed or to establish a title ””
4 later decisions quote this exact passage · from the majority““The courts of the state might perhaps feel bound to give effect to the service made as directed by its statutes, lint no court deriving its authority from another government will recognize a merely constructive service as bringing the person within the jurisdiction of the court. The judgment would be allowed no force in the courts of any other state, and it is of no greater force, as against a citizen of another state, in a court of the United States, though held within the state in which the judgment was rendered.” Id. 155.”
3 later decisions quote this exact passage · from the majority““Generally, if not universally, equity jurisdiction is exercised in personam, and not in rem, and depends upon the control of the court over the parties, by reason of their presence or residence, and not upon the place where the land lies in regard to which relief is sought. Upon a bill for the removal of a cloud upon title, as upon a bill for the specific performance of an agreement to convoy, the decree, unless otherwise expressly provided by statute, is clearly not a judgment in rem, establishing a title in land, but operates in personam only, by restraining the defendant from asserting his claim, and directing him to deliver up his deed to be canceled, or to execute a relief to the plaintiff. * * * Such a decree, being in personam merely, can only be supported, against a person who is not a citizen or resident of the state in which it is rendered, by actual service upon him within its jurisdiction; and constructive service by publication in a newspaper is not sufficient.””
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.