Holgate v. Eaton’s Empirical Analysis
116 U.S. 33 · 1885
Citation profile
26 federal appellate · 11 district · 19 state decisions
How this case has been cited
Cited by 81 later decisions (12 by the Supreme Court) — most recently October 1974 · most notably Menendez v. Holt (1888), Galliher v. Cadwell (1892)
26 federal appellate · 11 district · 19 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 James Taylor v. Nicholas Longworth
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 81 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““And even when time is not thus, either expressly or impliedly, of the essence of the contract, if the party seeking a specific performance has been guilty of gross laches, or has been inexcusably negligent in performing the contract on his part, or if there has, in the ■ intermediate period, been a material change of circumstances, affecting the rights, interests or obligations of the parties, in all such cases, courts of equity will refuse to decree any specific performance, upon the plain ground that it would be inequitable and unjust. * * * But ’ in all sueh eases the court expects the party to make out a case free from all doubts, and to show that the relief which he asks is, under all the circumstances, equitable, and to account in a reasonable manner for his delay, and apparent omission of his duty.””
3 later decisions quote this exact passage · from the majority“Time-may be made of the essence of the contract by express stipulation, or it may become essential by considerations- arising from the nature of the property or the character of the interest bargained. And the principle of the court of equity does not depend upon considerations collateral to the contract merely, nor on the conduct of the parties subsequently, showr ing that time was not of the- essence of the contract in the particular case. But it must affirmati/vehy appem' that the parties regarded time or place as an essential element in their agreement, or a court of equity will not so regard it.”
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.