Chase v. Curtis’s Empirical Analysis
113 U.S. 452 · 1885
Citation profile
23 federal appellate · 12 district · 48 state decisions
How this case has been cited
Cited by 123 later decisions (12 by the Supreme Court) — most recently August 1986 · most notably Huntington v. Attrill (1892), Wisconsin v. Pelican Insurance (1888)
23 federal appellate · 12 district · 48 state decisions — followed in 20 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 State of Louisiana Folsom v. Mayor Etc of the City of New Orleans · Flash v. Conn · Whitney Arms Co. v. . Barlow · O'Brien v. . Young
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 123 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is finally insisted that a judgment against the corporation, although founded upon a tort, becomes ipso facto a debt by contract, being a contract of record, or a specialty in the nature of a contract; but we have already seen that the settled course of decisions in the New York Court of Appeals rejects .the judgment against the corporation as either evidence or ground of liability against the trustees, and founds the latter upon the obligation of the corporation on which the judgment itself rests. And it was decided by this court in the case of Louisiana v. New Orleans, 109 U. S. 285 , 3 Sup. Ct. 211, 27 L. Ed. 936 , that a liability for a tort, created by statute, although reduced to judgment by a recovery for the damages suffered, did not thereby become a debt by contract in the sense of the Constitution of the United States forbidding state legislation impairing its obligation, for the reason that 'the term “contract” is used in the Constitution in its ordinary sense as signifying an agreement of two or more minds, for considerations proceeding from one to the other to do or not to do certain acts. Mutual assent to its terms is of its very essense.’ The same definition applies in the present instance and excludes the liability of the defendants, as trustees of the corporation, for its torts, although reduced to judgment.””
2 later decisions quote this exact passage · from the majority““Such claims are not within the contemplation of the act. The mischief to be prevented by its requirements has no relation to liabilities of that description. The creditors to be protected are those only who become such by voluntary transactions, in reference to which, for their benefit, the information becomes important as to the debts of the company.” 113 U. S. 462 , 5 Sup. Ct. 558 , 28 L. Ed. 1038 .”
1 later decision quote this exact passage · from the majority““If any of said companies shall fail so to do, all the trustees of the company shall be jointly and severally liable for all the debts of the company, then existing, and for all that shall be contracted before such report shall be made.””
1 later decision quote this exact passage
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.