Hoffman v. Chapman’s Empirical Analysis
1943
Citation profile
3 federal appellate · 5 district · 60 state decisions
How this case has been cited
Cited by 74 later decisions — most recently March 2016 · most notably McKeever v. Washington Heights Realty Corp. (1944), Trotter v. Lewis (1946)
3 federal appellate · 5 district · 60 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 Walden v. Skinner · Vincent v. Palmer · Markoff v. Kreiner · Columbian Nat. Life Ins. v. Black · Adams v. Henderson
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 74 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘A court of equity would be of little value,’ Justice Story said, ‘if it could suppress only positive frauds, and leave mutual mistakes, innocently made, to work intolerable mischiefs contrary to the intention of parties. It would be. to allow an act, originating in innocence, to operate ultimately as a fraud by enabling the party, who receives the benefit of the mistake, to resist the claims of justice under the shelter of a rule framed to promote it. * * * We must, therefore, treat the cases in which equity affords relief, and allows parol evidence to vary and reform written contracts and instruments, upon the ground of accident and mistake, as properly forming, like cases of fraud, exceptions to the general rule which excludes parol evidence, and as standing upon the same policy as the rule itself’.””
3 later decisions quote this exact passage · from the majority“It is a settled principle that a court of equity will reform a written instrument to make it conform to the real intention of the parties, when the evidence is so clear, strong and convincing as to leave no reasonable doubt that a mutual mistake was made in the instrument contrary to their agreement, [citations omitted.] It is a general rule of the common law that parol evidence is inadmissible to vary or contradict the terms of a written instrument, [citations omitted.] But equity refuses to enforce this rule whenever it is alleged that fraud, accident or mistake occurred in the making of the instrument, and will admit parol evidence to reform the instrument, even though it is within the Statute of Frauds, [citations omitted.] [Id. at 210, 34 A.2d at 439 .]”
2 later decisions quote this exact passage · from the majority““It is an established principle that a court of equity has the power to afford the remedy of reformation in order to make the instrument conform to the intent of the parties. * * * Equity will only act to reform the instrument if there is a mutual mistake of fact. It will not act on a mistake of law or of fact if the mistake is unilateral, save on the ground of fraud, duress or other inequitable conduct. * * * “Before granting the high remedy of reformation, the proof must not only establish that the written agreement was not the agreement intended by the parties, but also what was the agreement contemplated by them at the time it was executed. In many cases, the evidence, for the main part, is oral testimony. * *”
1 later decision quote this exact passage · from the majoritye.g. Mattingly v. Houston
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.