Francis v. Thomas’s Empirical Analysis
1937
Citation profile
69 state decisions
How this case has been cited
Cited by 76 later decisions — most recently March 2017 · most notably Cowden v. Bell (1957), Gulf Production Co. v. Continental Oil Co. (1939)
69 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 Hooks v. Bridgewater · Burns v. . McCormick · The Texas Co. v. Burkett · Clegg v. Brannan · Woolley v. . Stewart
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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘There must be performance “unequivocally referable” to the agreement, performance which alone and without the aid of words of promise is unintelligible or at least extraordinary unless as an incident of ownership, assured, if not existing. ‘ “An act which admits of explanation without reference to the alleged oral contract or a contract of the same general nature and purpose is not, in general, admitted to constitute a part performance.” Woolley v. Stewart, 222 N.Y. 347, 351 , 118 N.E. 847, 848 . ‘What is done must itself supply the key to what is promised. It is not enough that what is promised may give significance to what is done.’ ’’”
3 later decisions 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.