Rowland v. Kable’s Empirical Analysis
1940
Citation profile
5 federal appellate · 26 state decisions
How this case has been cited
Cited by 46 later decisions — most recently December 2014 · most notably Trayer v. Bristol Parking, Inc. (1956), Giannotti v. Hamway (1990)
5 federal appellate · 26 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 United States v. Carter · Wardell v. Railroad Co. · Marsh v. Whitmore · Ferguson & Fries v. Gooch · Waddy v. Grimes
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]his good faith forbids [a corporate officer from] placing himself in a position where his individual interest clashes with his duty to his corporation.”
7 later decisions quote this exact passage · from the majority““Now, therefore, in order to obtain the unanimous consent of all the undersigned parties who are the beneficiaries under the will of William G. Kable, deceased, and as such entitled to all the dividends declared by Staunton Military Academy, do agree as follows: “That the Board of Directors of Staunton Military Academy be requested by the undersigned beneficiaries to declare a dividend equal to 50% of such compromise settlement, after the payment of attorney’s fees, the entire amount of which dividend shall be paid to William G. Kable, II; and the undersigned beneficiaries do by these presents direct the said Staunton Military Academy to make payment of said dividend as above directed, and do further waive any and all rights that they might otherwise have in said dividend. “The residue of said settlement after payment of the amounts hereinbefore described, shall be held by Staunton Military Academy, and at their request be paid by said Academy to Eleanor Kable Miller, Helene Kable Ferguson and Eleanor E. Whitehead, in such amounts, and upon such terms and conditions, as they may agree upon.” (Italics ours.)”
1 later decision quote this exact passage · from the majority“good faith alone is not sufficient in the absence of full disclosure and consent of the interested parties . . . to make an exception to the general rule that a [corporate fiduciary] cannot enter into any relation or do any act inconsistent with the interest of the [corporation].”
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.