Rowson v. Rowson’s Empirical Analysis
1955
Citation profile
49 state decisions
How this case has been cited
Cited by 49 later decisions — most recently May 2011 · most notably Morrow v. Shotwell (1972), Westland Oil Development Corp. v. Gulf Oil Corp. (1982)
49 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 Wilson v. Fisher · Pickett v. Bishop · Matney v. Odom · Sanderson v. Sanderson · Broaddus v. Grout
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is apparent that the writing here does not itself contain a description of the property sufficient to lead to its identity or location with reasonable certainty. It not only contains no metes and bounds description, but gives no information as to location—neither the state, county, survey nor location where it may be found. “[p. 471] It is immaterial that the Denton County property was the property in the contemplation of the parties at the time the letters were written, or even that parol evidence leads the court to believe that the Denton County property was the subject matter of the contract. Unless the description contained in the writing leads to that conclusion with reasonable certainty the contract is unenforceable.””
2 later decisions quote this exact passage · from the majority““ * * * But the rule of law is equally clear that resort may not he had to extrinsic evidence to supply the description or location of land required by the Statute of Frauds to be contained in the writing. O’Herin v. Neal, Tex.Civ.App., 56 S.W.2d 1105 , writ refused. ‘ * * * resort to extrinsic evidence, where proper at all, is not for the purpose of supplying the location or description of the land, hut only for the purpose of identifying it with reasonable certainty from the data in the memorandum.’ Wilson v. Fisher, 144 Tex. 53 , 188 S.W.2d 150, 152 . “What the contract itself must contain to he enforceable is thus stated in Wilson v. Fisher: ‘ * * * the writing must furnish within itself, or by reference to some other existing writing, the means or data by which the particular land to be conveyed may be identified with reasonable certainty.’ This test has become the standard by which this Court measures the sufficiency of a writing. Pickett v. Bishop, 148 Tex. 207 , 223 S.W.2d 222, 224 ; Broaddus v. Grout, 152 Tex. 398 , 258 S.W.2d 308, 309 .””
1 later decision quote this exact passage · from the majority““But the rule of law is equally clear that resort may not be had to extrinsic evidence to supply the description or location of land required by the Statute of Frauds to be contained in the writing. O’Herin v. Neal, Tex.Civ.App., 56 S.W.2d 1105 , writ refused. * * *. “What the contract itself must contain to be enforceable is thus stated in Wilson v. Fisher [ 144 Tex. 53 , 188 S.W.2d 150 ]: ‘ * * * the writing must furnish within itself, or by reference to some other existing writing, the means or data by which the particular land to be conveyed may be identified with reasonable certainty.’ This test has become the standard by which-this Court measures the sufficiency of a writing. Pickett v. Bishop, 148 Tex. 207 , 223 S.W.2d 222, 224 ; Broaddus v. Grout, 152 Tex. 398 , 258 S.W.2d 308, 309 .” See Wilson v. Fisher, 144 Tex. 53 , 188 S.W.2d 150 .”
1 later decision quote this exact passage · from the majoritye.g. Wiseman v. Zorn
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.