Beck v. Semones' Administrator’s Empirical Analysis
1926
Citation profile
2 federal appellate · 23 state decisions
How this case has been cited
Cited by 26 later decisions — most recently July 2018 · most notably Wackwitz v. Roy (1992), Slaughter v. Commonwealth (1981)
2 federal appellate · 23 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 Windsor v. McVeigh · Ferguson v. . Crawford · White v. Crow · Anthony v. Kasey · Farant Investment Corp. v. Francis
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“When an officer of a corporation, either in his own right or as agent for another, sues the company of which he is the officer, he abandons for the occasion his position as officer and cannot commence an action against the company by service of process upon himself as officer. This would be simply service of process upon the plaintiff instead of upon the defendant. If this could be done and the judgment rendered thereon could not be collaterally assailed, it would open the door to the grossest fraud, and subvert the orderly administration of justice. Where the relation of the officer served to the plaintiff is such as to make it to his interest to suppress the fact of service, service cannot be made upon such officer, although he is within the terms of the statute designating those upon whom service may be made.”
1 later decision quote this exact passage · from the majority“[T]he fact that the trial court decided that such service or appearance was valid could not make it so. If the service or appearance was illegal, a decision of the trial court to the contrary could not make it legal. If such were true, then the trial court could never, under any circumstances, enter a void judgment.”
1 later decision quote this exact passage · from the majority“It is conceded by all authorities that if a judgment is void it may be assailed anywhere, at any time, in any way, by anybody.”
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.