Patnode v. Westenhaver’s Empirical Analysis
1902
Citation profile
1 federal appellate · 1 district · 23 state decisions
How this case has been cited
Cited by 26 later decisions — most recently December 1979 · most notably Dale v. Thomas H. Temple Co. (1948), Franklin Music Co. v. American Broadcasting Companies (1979)
1 federal appellate · 1 district · 23 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 Spies v. People · People v. Mather · Gibson v. State · Branch v. Faust · Baxter v. Chicago & Northwestern Railway 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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A mere tacit understanding between conspirators to work to a common purpose is all that is essential to a guilty, ac■tionable combination. . . . Mutuality in the undertaking may be secured without any express agreement and without a spoken or written word between the conspirators or a meeting of the members of the combine, or their, even, all knowing each other; or the precise thing to be accomplished or plans for its accomplishment, either in a general way or in detail, being distinctly stated by any member of the combine to any other member. If there is a meeting of minds, brought about in any way, to accomplish the common purpose, the essentials of a guilty combination are all satisfied.” Lange v. Heckel, 171 Wis. 59 , 175 N. W. 788 ; Wachowski v. Lutz, 184 Wis. 584, 593 , 201 N. W. 234 .”
2 later decisions quote this exact passage“The gist (of this action) is the damage suffered by a wrong which was distinct from other wrongs which were in a measure incidental thereto. * * * The cause of action for the conspiracy in such circumstances is a possession by itself, a right to prosecute for the damages caused by the executed fraudulent combination. * * * The right to redress for damages caused by a consummated conspiracy is distinct, so to speak, from the right to redress for wrongs caused in the progress of its execution. It may go against all the members of the combine, and there may be incidental transactions causing damage included in the claim against all, from which causes of action may arise against individual members of the combine. The prosecution of all for the conspiracy may proceed concurrently with the prosecution of one or more members of the combine liable for some element of the damage in another form of action, up to the point of satisfaction, at which point the element satisfied drops out, as there can be but one satisfaction for the same element of damage.”
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.