Meehan v. Valentine’s Empirical Analysis
145 U.S. 611 · 1892
Citation profile
100 federal appellate · 11 district · 100 state decisions
How this case has been cited
Cited by 308 later decisions (19 by the Supreme Court) — most recently July 2009 · most notably Commissioner of Internal Revenue v. Culbertson (1949), Commissioner v. Tower (1946)
100 federal appellate · 11 district · 100 state decisions — followed in 22 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 Central Transportation Co. v. Pullman's Palace Car Co. · Pleasants v. Fant · Eber Ward Survivor Owner of the Steamboat Detroit v. Charles Thompson · Beckwith v. Talbot
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 308 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The requisites of a partnership are that the parties must have joined together to carry on a trade or adventure for their common benefit, each contributing property or services, and having a community of interest in the profits.””
15 later decisions quote this exact passage · from the majority““ ‘In the present state of the law upon this subject, it may perhaps be doubted whether any more precise general rule can be laid down than, as indicated at the beginning of this opinion, that those persons are partners who contribute either property or money to carry on a joint business for their common benefit, and who own and share the profits thereof in certain proportions. If they do this, the incidents or consequences follow that the acts of one in conducting the partnership business are the acts of all, that each is agent for the firm and for the other partners, that each receives part of the profits as profits, and takes part of the fund to which the creditors of the partnership have a right to look for the payment of their debts, that all are liable as partners upon contracts made by any of them with third persons within the scope of the partnership business, and that even an express stipulation between them that one shall not be so liable, though good between themselves, is ineffectual as against third persons. And participating in profits in presumptive, but not conclusive, evidence of partnership.’ ””
8 later decisions quote this exact passage · from the majority““The rule formerly laid down, and long acted on as established, was that a man who received a certain share of the profits as profits, with a lien on the whole profits as security for his share, was liable as a partner for the debts of the partnership, even if it had been stipulated between him and his copartners that he should not be so liable; but that merely receiving compensation for labor or services, estimated by a certain proportion of the profits, did not render one liable as a partner. Story, Partn., c. 4; 3 Kent, Comm. 25, note 32-34; Ex parte Hamper [17 Ves. 403], above cited; Pott v. Eyton, 3 C. B, 32, 40; Bostwick v. Champion, 11 Wend. [N. Y.] 571, and [Id.] 18 Wend. [N. R.] 175, 184, 185, [31 Am. Dee. 376]; Burckle v. Eckart, 1 Denio [N. Y.] 337, and [Id.] 3 N. Y. 132 ; Denny v. Cabot, 6 Metc. (Mass.) 82; Fitch v. Harrington, 13 Gray [Mass.] 468, 474 [ 74 Am. Dec. 641 ]; Brundred v. Muzzy, 1 Dutcher (25 N. J. Law) 268, 279, 674. The test was often stated to be whether the person sought to be charged as a partner took part of the profits as a principal or only as an agent. Benjamin v. Porteus, 2 H. Bl. 590, 592; Coll. Partn. (1st Ed.) 14; Smith, Merc. Law (1st Ed.) 4; Story, Partn., sec. 55; Loomis v. Marshall, 12 Conn. 69, 78 [ 30 Am. Dec. 596 ]; Burckle v. Eckart, 1 Denio [N. Y.] 337, 341; Hallet v. Desban, 14 La. Ann. 529 .””
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.