Way v. Turner’s Empirical Analysis
1916
Citation profile
2 federal appellate · 6 district · 10 state decisions
How this case has been cited
Cited by 18 later decisions — most recently October 2001
2 federal appellate · 6 district · 10 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 Keener v. Harrod · Blake v. Stump · Walker v. Baldwin & Frick · Livezy v. Miller · Martien v. Mayor of Baltimore
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 18 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The rule of law applicable to, this description of cases has been frequently announced in nearly every state in this country, with some slight variations of ,phraseology. It is concisely summed up in 4 R.C.L. p. 298, § 43, as follows: ‘It is not enough that the broker has devoted his time, labor, or money to the interest of his principal, as unsuccessful efforts, however meritorious, afford no ground of action. And it matters not that after his failure and the termination of his agency what he has done proves of use and benefit to the principal. In a multitude of cases that must necessarily result. He may have introduced to each other parties who otherwise would never have met; he may have created impressions which under later and more favorable circumstances naturally lead to and materially assist in the consummation of a sale; he may have planted the very seed from which others reaped the harvest; but all that gives him no claim. It was part of his risk that, failing himself, not successful in fulfilling his obligation, others might be left to some extent to avail themselves of the fruit of his labor. To entitle a broker to commissions upon a sale or transaction which is actually consummated, he must show that his efforts and services were the primary, proximate, and procuring cause thereof.’ And for this statement the author cites, among other cases Keener v. Harrod, 2 Md. [63], 70, 56 Am.Dec. 706 ; Tinges v. Moale, 25 Md. 480 , 90 Am.Dec. 73 ; and Blake v. Stump, 73 Md. ”
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.