Young Women's Christian Home v. French’s Empirical Analysis
187 U.S. 401 · 1903
Citation profile
11 federal appellate · 9 district · 46 state decisions
How this case has been cited
Cited by 70 later decisions (1 by the Supreme Court) — most recently May 1965 · most notably Red 'C' Oil Manufacturing Company v. Board of Agriculture of North Carolina a H C (1912), Coulter v. Louisville & Nashville Railroad (1905)
11 federal appellate · 9 district · 46 state decisions — followed in 16 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 District of Columbia Circuit Court of Appeals)
Relationships
Relies on John Smith v. Robert Bell · Kenaday v. Sinnott · Metcalf v. First Parish in Framingham · Clarke v. Boorman's Executors
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 70 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The rule is that there is no presumption of survivorship in the case of persons who perish by a com mon disaster, in the absence of proof tending to show the order of dissolution, and that circumstances surrounding a calamity of the character appearing on this record are insufficient to create any presumption on which the courts can act. The question of actual survivorship is regarded as unascertainable, and descent and distribution take the same course as if the deaths had been simultaneous. ’ ’”
3 later decisions quote this exact passage · from the majority““Where a devise is limited to take effect upon a condition or contingency annexed to a preceding estate, if that preceding estate should not arise, the remainder over will take place; the first estate being considered as a preceding limitation, and not as a preceding condition. * ® * As when a testator meant to dispose of all his property and uses the words ‘if the legatee should not survive,’ held to mean ‘if the preceding legacy should from any cause fail.’ ””
1 later decision quote this exact passage · from the majoritye.g. Fitzgerald v. Ayres“The terms of the will “ ‘vesting the estate in Eugene Rhodes immediately upon testatrix’s death, we agree that it raises a prima facie right in the personal representatives of the son, and imposes the burden upon her next of kin of displacing them by proof of his mother’s survival,’ and that the representatives and next of kin of the son were entitled to the entire fund.””
1 later decision quote this exact passagee.g. Fitzgerald v. Ayres
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.