Guthrie v. Harkness’s Empirical Analysis
199 U.S. 148 · 1905
Citation profile
64 federal appellate · 13 district · 152 state decisions
How this case has been cited
Cited by 290 later decisions (19 by the Supreme Court) — most recently November 2021 · most notably Koster v. Lumbermens Mut Casualty Co (1947), Marsh v. State of Alabama (1946)
64 federal appellate · 13 district · 152 state decisions — followed in 39 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 Trustees of Dartmouth College v. Woodward · United States v. Wong Kim Ark · Smith v. State of Alabama · Davis v. Elmira Savings Bank · Edward Prigg v. Commonwealth of Pennsylvania
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 290 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'though their only object is to ascertain whether their affairs have been properly conducted by the directors or managers.'”
5 later decisions quote this exact passage · from the majority“'for speculative purposes or to gratify idle curiosity or to aid a blackmailer.'”
4 later decisions quote this exact passage · from the majority““But do the defendants, or either of them, propose the exercise of visitorial authority? We think not. Visitation, in law, is the act of a superior or superintending officer, who visits a corporation to examine into its manner of conducting business, and enforce an observance of its laws and regulations. Burrill defines the word to mean ‘inspection; superintendence; direction; regulation.’ The exercise of no such authority is contemplated by defendants. They do not contemplate inspection, supervision, or regulation of complainant’s business, or an enforcement of its laws or regulations. On the contrary) their purpose is to ascertain, in a legal way, and by legitimate testimony, whether any person had, at the time mentioned, on deposit with complainant any money subject to taxation in said county which had not been returned by the owners thereof for that purpose. Hence, the subpoena commanding the production of the complainant’s books, in the manner and for the purpose stated, is not an exercise of ‘visitorial powers;’ and it follows that the witness is not protected by said section from amenability to the probate court for his contempt in disobeying its mandate.””
3 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.