Smith v. Woolfolk’s Empirical Analysis
115 U.S. 143 · 1885
Citation profile
12 federal appellate · 8 district · 13 state decisions
How this case has been cited
Cited by 49 later decisions (6 by the Supreme Court) — most recently December 1952 · most notably Richmond v. Irons (1887), Kilbourn v. Sunderland (1889)
12 federal appellate · 8 district · 13 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 Pennoyer v. Neff · William Shields v. Robert R Barrow · Windsor v. McVeigh · Harkness v. Hyde · Hardin v. Boyd
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is settled that one defendant cannot have a decree against a co-defendant without a cross bill, with proper prayer, and process or' answer a.s in an original suit. Walker v. Byers, 14 Ark. 246 ; Gantt’s Dig. § 4559; Cullum v. Erwin, 4 Ala. 452 ; Cummins v. Gill, 6 Ala. 562 ; Shelby v. Smith, 2 A. K. Marshall, 504. It follows, from the reason of this rule, that if one complainant can, under any circumstances, have a decree against another upon a supplemental or amended bill, it must be upon notice to the latter. After a decree disposing of the issues and in accordance with the prayer of a bill has been made, it is not competent for one of the parties, without a service of new process or appearance, to institute further proceedings, on new issues and for new objects, although connected with the subject-matter of the original litigation, by merely giving the new proceedings the title of the original cause. If his bill begins a new litigation, the parties against whom he seeks relief are entitled to notice thereof, and without it they will not be bound; for the decree of a court rendered against a party who has not been heard, and has had no chance to be heard, is not a judicial determination of his rights,, and is not entitled to respect in any other court.””
2 later decisions quote this exact passage · from the majority““We are of opinion that the decree of the Chicot circuit court, made on the twenty-eighth day of October, 1878, was, so far as it concerned Joseph S. Woolfolk and Lucy D., his wife, a final decree in the cause, and - they were bound to take no notice of the subsequent proceedings, unless they were served with process or entered their voluntary appearance.’’”
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.