Walker & Austin v. Tyler’s Empirical Analysis
130 F.2d 303 · 1942
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 18 later decisions — most recently June 1994
7 federal appellate · 1 district ·
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
Applies 11 U.S.C. § 501 · 11 U.S.C. § 701
Relies on Securities & Exchange Commission v. United States Realty & Improvement Co. · Lane v. Haytian Corp. · Fuller v. Memphis Street Ry. Co. · Kuhn, Loeb & Co. v. Paramount Publix Corp. · New York & Cuba Mail Steamship Co. v. Continental Insurance Co.
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.
“[T]he very tenuous statutory basis for any allowance does not seem to us to justify awards for uncertain and somewhat problematical benefits thus conferred on the administration of an estate before it has begun. The difficulty is in seeing where much of any line can be drawn to reduce the potential contribution for prior activities during the always-occurring prior period of financial stress. Activities supporting the management will be beneficial as aimed at avoiding the disaster of bankruptcy; while activities opposing its excesses will be beneficial as hastening the curative and cleansing course of reorganization. The cases emphasize that when such allowances are made they must be for work which “directly contributes” to the reorganization; thus we have held that compensation is not allowable from the estate “for the work of the attorneys in conserving the debtor’s assets” as well as in proposing an arrangement differing from the reorganization finally effected.... To have this direct connection it would seem that the services must not only be ultimately beneficial in some clearly observable way, but also have been directed toward the specific rehabilitation of the debtor which actually took place. Chance and unwitting action, or activities a year or so earlier to control the course of creditor pressure upon the debtor, would seem clearly outside the narrow limits of the precedents, even if these in turn do go somewhat beyond the literal statutory language, (footnotes and ”
2 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.