Snyder v. Cearfoss’s Empirical Analysis
1947
Citation profile
39 state decisions
How this case has been cited
Cited by 39 later decisions — most recently April 2022 · most notably Pullman Co. v. Ray (1953), Eisenberg, Admin. v. Air Cond., Inc. (1961)
39 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 Snyder v. Cearfoss · Columbus Construction Co. v. Crane Co. · Rio Grande Irrigation & Colonization Co. v. Gildersleeve · Lichtenberg v. Joyce · Bryant v. Bryant
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But it is also true that forbearance to sue for a lawful claim or demand is sufficient consideration for a promise to pay for the forbearance, if the party forbearing had an honest intention to prosecute litigation, which is not frivolous, vexatious or unlawful, and which he believed to be well founded, even though it may in fact be unfounded. Hartle v. Stahl, 27 Md. 157 ; Bowen v. Tipton, 64 Md. 275, 288 , 1 A. 861 ; Emmitsburg R. Co. v. Donoghue, 67 Md. 383, 389 , 10 A. 233 , 1 Am. St. Rep. 396 , We adopt the rule stated by the American Law Institute that forbearance to assert an invalid claim by a person who has not an honest and reasonable belief in its possible validity is not sufficient consideration for a contract of forbearance. 1 Restatement, Contracts, Sec. 76(b). We thus combine the requisite that the claim be made in good faith with the requisite that it must be reasonably doubtful. While emphasis is placed on the honesty and good faith of the claimant, forbearance is insufficient consideration if the claim forborne is so lacking in foundation as to make its assertion incompatible with honesty and a reasonable degree of intelligence. 1 Williston on Contracts, Rev. Ed., Sec. 135.””
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.