Zimmerman v. Rose’s Empirical Analysis
1922
Citation profile
2 federal appellate · 10 state decisions
How this case has been cited
Cited by 14 later decisions — most recently July 2011
2 federal appellate · 10 state decisions
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 Leslie v. Gibson · Va. Fire & Marine Ins. v. Cottrell · Marshall v. Shepard · Young v. Martin · Haish v. Pollock
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"In some states it is held that before the confirmation of a judicial sale the bidder is not a purchaser, but that after the confirmation the contract is complete. Virginia Fire, etc., Ins. Co. v. Cottrell, 85 Va. 857 , 9 S.E. 132 , 17 Am.St.Rep. 108 . Undoubtedly this is true for certain purposes, because the bidder may be compelled by proceedings of the court to comply with his contract. But obviously he is not the owner of the legal title until he has complied and the deed has been executed. * * * (Emphasis supplied.) "But while these rights and liabilities accrue on confirmation we think it is because the equitable title passes to the purchaser after confirmation and before the deed is executed. "The property is held in trust for the purchaser between the time of sale and the time when the conveyance is made to him. Still, he does not obtain the legal title by such confirmation unless the decree divests and vests title, or a deed is made by the master or officer selling pursuant to a decree ordering him to do so, or unless on being so ordered, the master fails to make the deed within a reasonable time.' 16 R.C.L. 117."”
1 later decision quote this exact passage · from the majoritye.g. Brewster v. Herron““The effect of the former decisions is to hold that the equitable title is vested in the purchaser, after the confirmation of the sale, and that he thereby obtains certain vested rights and incurs certain obligations which, in a proper case, could be asserted or enforced.” (p. 25.)”
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.