Chicago Ry Co v. Sturm’s Empirical Analysis
174 U.S. 710 · 1899
Citation profile
50 federal appellate · 27 district · 124 state decisions
How this case has been cited
Cited by 280 later decisions (27 by the Supreme Court) — most recently June 2017 · most notably Shaffer v. Heitner (1977), Estin v. Estin (1948)
50 federal appellate · 27 district · 124 state decisions — followed in 35 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 Pullman's Palace-Car Co v. Commonwealth of Pennsylvania · Kirtland v. Hotchkiss · Savings Loan Soc v. Multnomah County or · Wyman v. United States
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 280 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“' "All debts are payable everywhere, unless there be some special limitation or provision in respect to the payment; the rule being that debts as such have no locus or situs, but accompany the creditor everywhere, and authorize a demand upon the debtor everywhere.”
3 later decisions quote this exact passage · from the majority“The essential service of foreign attachment laws is to reach and arrest the payment of what is due and might be paid to a nonresident to the defeat of his creditors. To do it, you must go to the domicile of his debtor [ (the garnishee) ], and can only do it under the laws and procedure in force there. This is a legal necessity, and considerations of situs are somewhat artificial. If not artificial, whatever of substance there is must be •with the [garnishee]. He, and he only, has something in his hands. That something is the res, and gives character to the action, as one in the nature of a proceeding in rem. To ignore this is to give immunity to debts owed to nonresident [garnishment debtors] from attachment by their [garnishment] creditors, and to deny necessary remedies.”
2 later decisions quote this exact passage · from the majority““A debt may be as valuable as tangible things. It is not capable of manual seizure, as they are; but no more than they can it be appropriated by attachment without process and the power to execute process. A notice to a debtor must be given, and can only be given and enforced where he is. This, as we have already said, is a necessity, and it cannot be evaded by the insistence upon fiction or refinements about situs or the rights of the creditor. Of course, the debt is the property of the creditor; and, because it is, the law seeks to subject it, as it does other property, to the payment of his creditors. If it can be done in any way than by process against and jurisdiction of his debtor, that way does not occur to us.””
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.