Glover v. Patten’s Empirical Analysis
165 U.S. 394 · 1897
Citation profile
27 federal appellate · 6 district · 84 state decisions
How this case has been cited
Cited by 134 later decisions (4 by the Supreme Court) — most recently April 2025 · most notably Swidler & Berlin v. United States (1998), In Re the Investigation of the Death of Miller (2003)
27 federal appellate · 6 district · 84 state decisions — followed in 28 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.
Appellate journey
reviewedthe decision below (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on Hunt v. Blackburn · Blackburn v. Crawfords · Shepherd v. Thompson · Reynolds v. . Robinson
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 134 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“... we are of the opinion that, in a suit between the devisees under a will, statements made by the deceased to counsel respecting the execution of the will, or other similar document, are not privileged. While such communications might be privileged if offered by third persons to establish claims against an estate, they are not within the reason of the rule requiring their exclusion, when the contest is between the heirs or next of kin.”
8 later decisions quote this exact passage · from the majority““The client may waive the protection of the rule. The waiver may be expressed or implied. We think it as effectual here by implication as the most explicit language could have made it. It could have been no clearer if the client had expressly enjoined it upon the attorney to give this testimony whenever the truth of his testamentary declaration should be challenged by any of those to whom it related. A different result would involve a perversion of the rule, inconsistent with its object, and in direct conflict with the reasons upon which it is founded.””
1 later decision quote this exact passage · from the majority“a solicitor, by whom the will was drawn, should be allowed to testify what was said by the testator contemporaneously upon the subject.”
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.