Freeman v. Alderson’s Empirical Analysis
119 U.S. 185 · 1886
Citation profile
33 federal appellate · 9 district · 137 state decisions
How this case has been cited
Cited by 245 later decisions (15 by the Supreme Court) — most recently July 2018 · most notably Shaffer v. Heitner (1977), Tennessee Student Assistance Corporation v. Hood (2004)
33 federal appellate · 9 district · 137 state decisions — followed in 35 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 Pennoyer v. Neff · Cooper v. Reynolds
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 245 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“There is, however, a large class of cases which are not strictly actions in rem, but are frequently spoken of as actions quasi in rem, because, though brought against persons, they only seek to subject certain property of those persons to the discharge of the claims asserted. Such are actions in which property of nonresidents is attached and held for the discharge of debts due by them to citizens of the State, and actions for the enforcement of mortgages and other liens. Indeed, all proceedings having for their sole object the sale or other disposition of the property of the defendant; to satisfy the demands of the plaintiff, are in a general way thus designated. (Emphasis added.)”
1 later decision quote this exact passage · from the majority““Every state owes protection to its own citizens, and, wlien nonresidents deal with them, it is a legitimate and just exercise of authority to hold and Appropriate any property owned by such nonresidents to satisfy Hie claims of its citizens. It is in virtue of the state’s jurisdiction over the property of the nonresident situated within its limits that its tribunals can inquire into that nonresident’s obligations to its own citizens, and the inquiry can then be carried only to the extent necessary to control the disposition of the property.””
1 later decision quote this exact passage · from the majority““Such are actions in which property of nón-residents is attached and held for the discharge of debts due by them to citizens of the state, and actions for the enforcement of mortgage and other liens. Indeed, all proceedings having for their sole object the sale or other disposition of the property of the defendant to satisfy the demand of the plaintiff are in a general way thus designated.” (Freeman v. Alderson, 119 U. S. 187 ; Black, Judgm., § 793.)”
1 later decision quote this exact passage · from the majoritye.g. Cackley v. Smith
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.