Johnson v. Waters’s Empirical Analysis
111 U.S. 640 · 1884
Citation profile
98 federal appellate · 13 district · 33 state decisions
How this case has been cited
Cited by 259 later decisions (35 by the Supreme Court) — most recently June 1999 · most notably Hazel-Atlas Glass Co. v. Hartford-Empire Co. (1944), Ortiz v. Fibreboard Corp. (1999)
98 federal appellate · 13 district · 33 state decisions — followed in 15 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 Gaines v. Fuentes · Barrow v. Hunton · Jackson v. Ludeling · Dawson v. Holbert
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 259 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A court of ‘chancery is always open to hear complaints against fraud, whether committed in pais, or in or by moans of judicial proceedings.’ ” Marshall v. Holmes. 141 U. S. 599 , 12 Sup. Ct 62 , 35 L. Ed. 870 , quoting from Johnson v. Waters, 111 U. S. 640 , 667, 4 Sup. Ct. 619 , 28 L. Ed. 547 . “In such cases, the court does not act as a court of review, nor does it inquire into any irregularities or errors of proceeding in another court; but it will scrutinize the conduct of the parties, and, if it finds that they have been guilty of fraud in obtaining a judgment or decree, it will deprive them of the benefit of it, and of any inequitable advantage which they have derived under it.” Johnson v. Waters, supra.”
11 later decisions quote this exact passage · from the majority““Had the question of fraud been before the probate court in any of these proceedings, and had the complainant been apprised of them, the case might have been different. This court would not try over again a case already tried, nor permit the complainant to litigate matters which he had notice of, and which he had an opportunity to litigate in the probate proceedings. But one of the grounds of complaint made by the bill is that the very attorneys whom he had employed to secure his claim acted as attorneys for the succession and heirs, and conducted the proceedings for the sale, and participated as active parties therein, without giving him any notice of what was being done.””
2 later decisions quote this exact passage · from the majority““In the one class, there would be a more revision of errors and irregularities, or of the legality and correctness of the judgments and decrees, of the state courts; and, in the other class, the investigation of a new case, arising upon new facts, althougli haying relation to the validity of an actual judgment or decree, or of the party’s right to claim any benefit by reason thereof.””
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.