Sayers v. Bullar’s Empirical Analysis
1942
Citation profile
3 federal appellate · 2 district · 50 state decisions
How this case has been cited
Cited by 78 later decisions — most recently May 2010 · most notably Messina v. Burden (1984), Elder v. Holland (1967)
3 federal appellate · 2 district · 50 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. Lee · Poindexter v. Greenhow · Cooper v. O'Connor · Cannon v. Montgomery · 99 W. Va. 397 - Mahone v. State Road Commission
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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A State cannot be sued except by its permission, and even if the suit, in form, be against the officers and agents of the State, yet if, in effect, it be against the State, is is not maintainable. Sections 2578 to 2583 of the Virginia Code (Michie) [now §§ 8-752 to 8-757, Code 1950] provide the only cases and the procedure in which actions may be maintained against the State. * See also Eriksen v. Anderson, 195 Va. 655, 658 , 79 S. E. 2d 597, 599 .”
3 later decisions quote this exact passage · from the majority“On the other hand, it is quite clear from the allegations and the averments of the [amended motion for judgment] . . . that they were acting solely in their representative capacity as lawful and proper agents of the State [or locality] and not in their own individual right.”
3 later decisions quote this exact passage · from the majoritye.g. James v. Jane · Messina v. Burden“[T]he immunity of the State from actions for tort extends to State agents and employees where they are acting legally and within the scope of their employment, but if they exceed their authority and go beyond the sphere of their employment, or if they step aside from it, they do not enjoy such immunity when they are sued by a party who has suffered injury by their negligence.”
2 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.