Minifie v. Rowley’s Empirical Analysis
1921
Citation profile
25 federal appellate · 6 district · 133 state decisions
How this case has been cited
Cited by 185 later decisions — most recently September 2018 · most notably Minton v. Cavaney (1961), Zaist v. Olson (1967)
25 federal appellate · 6 district · 133 state decisions — followed in 15 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.
Relationships
Relies on Llewellyn Iron Works v. Abbott Kidney Co. · Concannon v. Smith · Treweek v. Howard · Biddel v. Brizzolara · Cooley v. Miller & Lux, Inc.
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 185 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the separateness of the corporation has ceased and 'the facts are such that an adherence to the fiction of the separate existence of the corporation would ... sanction a fraud or promote injustice.'”
3 later decisions quote this exact passage““On June 3, 1915, defendant Forrest S. Rowley was appointed an executor of the will of Samuel Jones, the last surviving partner of the firm to which the debt herein sued upon is alleged to have been due. ‘The naming of a person as executor does not thereby discharge him from any just claim which the testator has against him, but the claim must be included in the inventory, and the executor is liable for the same, as for so much money in his hands when the debt or demand becomes due.’ (Code Civ. Proc., sec. 1447.) As a necessary consequence, if defendant Forrest S. Rowley owed the ten thousand dollars here in controversy on June 3, 1915, when he became executor, he became chargeable with that sum as for so much money in his hands and continued liable therefor, irrespective of the running of the period of the statute of limitations against the debt itself, by reason of the change in the character of his obligation due to his intervening fiduciary capacity. (Treweek v. Howard, 105 Cal. 434 [ 39 Pac. 20 ].) ””
1 later decision quote this exact passage““It is not necessary, as defendants contend, that the complaint allege actual fraud; it is sufficient if the facts set forth disclose that the dealings were in form with a corporation but in reality with an individual and that a refusal to recognize this fact will bring about inequitable results.””
1 later decision quote this exact passage
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.