Howe v. Howe’s Empirical Analysis
1942
Citation profile
3 federal appellate · 15 state decisions
How this case has been cited
Cited by 25 later decisions — most recently February 2023 · most notably 28 Cal. 2d 243 - Crouch v. Crouch (1946), Hertz Corp. v. Alamo Rent-A-Car, Inc. (1994)
3 federal appellate · 15 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 John Haddock v. Harriet Haddock · Andrews v. Andrews · Annie Andrews v. Kate H Andrews · Heflin v. Heflin · Chandler v. Chandler
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Since the Arkansas decree was void, Mrs. Howe could have utterly disregarded it, as something nonexistent. It would be no more logical to have some statute to declare that after a stated time had passed no attack should be made upon this stillborn judgment. Time touches defective decrees but in passing can give no vital force to them. Which, in legal contemplation, might as well have never been written. An attempt to apply either laches or limitations to this decree would be an attempt to apply them to something which was not there, to give substance to a ghost.”
1 later decision quote this exact passage · from the majority“‘If a judgment be null, no action on the part of the plaintiff, no inaction upon the part of the defendant, no resulting equity in the hands of the third persons, can invest it with any of the elements of power or vitality.’ It has been a long time since life was breathed into a dead body.”
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.