Zaist v. Olson’s Empirical Analysis
1967
Citation profile
12 federal appellate · 27 district · 139 state decisions
How this case has been cited
Cited by 192 later decisions — most recently June 2020 · most notably Angelo Tomasso, Inc. v. Armor Construction & Paving, Inc. (1982), Saphir v. Neustadt (1979)
12 federal appellate · 27 district · 139 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 Carl Fisser and Martha Fisser, Co-Partners Doing Business Under the Firm Name and Style of Fisser & v. Doornum, Libelants-Appellants v. International Bank · Minifie v. Rowley · Lowendahl v. Baltimore & Ohio Railroad · Wenban Estate, Inc. v. Hewlett · Kathryn E. Steven, Administratrix of the Estate of George A. Steven, Deceased v. Roscoe Turner Aeronautical Corporation
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 192 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) [c]ontrol, not mere majority or complete stock control, but complete domination, not only of finances but of policy and business practice in respect to the transaction attacked so that the corporate entity as to this transaction had at the time no separate mind, will or existence of its own; (2) that such control must have been used by the defendant to commit fraud or wrong, to perpetrate the violation of a statutory or other positive legal duty, or a dishonest or unjust act in contravention of the plaintiff's legal rights; and (3) that the aforesaid control and breach of duty must proximately cause the injury or loss complained of.”
18 later decisions quote this exact passage“"If plaintiff can show that there was such a unity of interest and ownership that the independence of the corporations had in effect ceased or had never begun, an adherence to the fiction of separate identity would serve only to defeat justice and equity by permitting the economic entity to escape liability arising out of an operation conducted by one corporation for the benefit of the whole enterprise." (citations omitted)”
12 later decisions quote this exact passage“`Courts will disregard the fiction of a separate legal entity when a corporation is a mere instrumentality or agent of another corporation or individual owning all or most of its stock. . . . Under such circumstances the general rule, which recognizes the individuality of corporate entities and the independent character of each in respect to their corporate transactions, and the obligations incurred by each in the course of such transactions, will be disregarded, where, as here, the interests of justice and righteous dealing so demand. . . . The circumstances that control is exercised merely through dominating stock ownership, of course, is not enough. . . . There must be such domination of finances, policies and practices that the controlled corporation has, so to speak, no separate mind, will or existence of its own and is but a business conduit for its principal.'”
4 later decisions quote this exact passage
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.