United States v. Beebe’s Empirical Analysis
180 U.S. 343 · 1901
Citation profile
189 federal appellate · 33 district · 41 state decisions
How this case has been cited
Cited by 519 later decisions (2 by the Supreme Court) — most recently September 2018 · most notably Hazel-Atlas Glass Co. v. Hartford-Empire Co. (1944), Teodore Dorotee Autera v. Manuel Dudley Robinson, Anthony C. Autera v. Manuel Dudley Robinson (1969)
189 federal appellate · 33 district · 41 state decisions — followed in 14 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 Fifth Circuit Court of Appeals)
Relationships
Relies on United States v. Throckmorton · United States v. Kirkpatrick · Robb v. Vos · Barrett v. . the Third Avenue R.R. Co.
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 519 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““■Where an agent has acted without' authority and It is claimed that the principal has thereafter ratified his act, such ratification can only lie hast'd upon a full knowledge of all the facts upon which the unauthorized action was taken, '.Phis is as true in the case of the government as in that of an individual. Knowledge is necessary in any event Story on Agency (9th Ed.) § 239, notes 1 and 2. If there he want of it, though such want arises from tin: neglect of the principal, no ratification can he based upon any act of his. Knowledge of ilie fads is the essential element of ratification, and must be shown or such facts proved 1hat ifs existence is a necessary inference from them.””
9 later decisions quote this exact passage · from the majority“the utter want of power of an attorney, by virtue of his general retainer only, to compromise his client's claim, cannot, we think, be successfully disputed.”
8 later decisions quote this exact passage · from the majority““Although an attorney at law, merely as such, has strictly speaking, no right to make a compromise; yet a Court would be disinclined to disturb one which was not so unreasonable in itself as to be exclaimed against by all, and to create an impression that the judgment of the attorney has been imposed upon, or not fairly exercised in the case. But where the sacrifice is such as to leave it scarcely possible that, with a full knowledge of every circumstance, such a compromise could be fairly made, there could be no hesitation in saying that the compromise, being unauthorized, and being therefore in itself void, ought not to bind the injured party.” Holker v. Parker, supra, 7. Cranch at 452.”
4 later decisions 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.