Egan v. United States’s Empirical Analysis
137 F.2d 369 · 1943
Citation profile
54 federal appellate · 1 district · 8 state decisions
How this case has been cited
Cited by 79 later decisions (2 by the Supreme Court) — most recently February 2019 · most notably Copperweld Corporation v. Independence Tube Corporation (1984), Commonwealth v. Beneficial Finance Company (1971)
54 federal appellate · 1 district · 8 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 Wickard v. Filburn · Virginian Ry Co v. System Federation No 40 · United States v. Darby · Braverman v. United States · Sparf v. United States
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 79 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The test of corporate responsibility for the acts of its officers and agents, whether such acts be criminal or tortious, is whether the agent or officer in doing the thing complained of was engaged in ‘employing the corporate powers actually authorized’ for the benefit of the corporation ‘while acting within the scope of his employment in the business of the principal.’ If the act was so done it will be imputed to the corporation whether covered by the agent or officer’s instructions, whether contrary to his instructions, and whether lawful or unlawful. Such acts under such circumstances are not ultra vires even though unlawful. There is no longer any distinction in essence between the civil and criminal liability of corporations, based upon the element of intent or wrongful purpose. Malfeasance of their agents is not ultra vires. * * * The court is not concerned with whether political contributions were authorized by a resolution of the board of directors or acquiesced in by a majority of the board. Our inquiry concerns only the powers of the corporation, the business it was authorized to carry on in the exercise of those powers, and whether the officers of the company in making political contributions were engaged in carrying on that business within the scope of their official duties. * ‡ * * * “The trial court correctly submitted the question of the defendant’s corporate responsibility to the jury, and this court cannot set aside the jury’s verdict.””
1 later decision quote this exact passage · from the majority““Where the accused is not in some ■ * * * interested relation to the conspirators * * mere knowledge * * * will be insufficient,' in the absence of some word or deed, to connect him with the conspiracy. * * * On the other hand * * * if he has some interest in the success of the conspirators * * * if the conspirators inform him of their plan and keep him advised of the steps taken by them to attain their purpose, and he by his approval stimulates their activities * * * then a jury upon evidence of such facts would be warranted in finding him guilty.””
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.