Hansen v. 75 Ranch Co.’s Empirical Analysis
1998
Citation profile
3 federal appellate · 2 district · 51 state decisions
How this case has been cited
Cited by 60 later decisions — most recently August 2023 · most notably Kauffman-Harmon v. Kauffman (2001), In Re the Estate of Bradshaw (2001)
3 federal appellate · 2 district · 51 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 Carbon County v. Union Reserve Coal Co., Inc. · Voeller v. Neilston Warehouse Co. · Dagel v. City of Great Falls · First SEC. Bank of Bozeman v. Goddard · In Re the Marriage of Jorgensen
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Applying a discount is inappropriate when the shareholder is selling her shares to a majority shareholder or to the corporation. The sale differs from a sale to a third party and, thus, different interests must be recognized. When selling to a third party, the value of the shares is either the same as or less than it was in the hands of the transferor because the third party gains no right to control or manage the corporation. However, a sale to a majority shareholder or to the corporation simply consolidates or increases the interests of those already in control. Therefore, requiring the application of a minority discount when selling to an 'insider' would result in a windfall to the transferee. This is particularly true since the transferring shareholder would expect that the shares would have at least the same value in her hands as in the hands of the transferee.... Since there is no 'market' involved in an inside transfer of shares, the minority discount should not be applied" ( Hansen , 957 P.2d at 41 ; accord Brown , 2006 WY 107 , ¶ 41, 141 P.3d at 687 ; Arnaud v. Stockgrowers State Bank of Ashland, Kansas , 268 Kan. 163 , 169, 992 P.2d 216 , 220 [1999] ; see also Brown v. Allied Corrugated Box Co. , 91 Cal.App.3d 477 , 486, 154 Cal.Rptr. 170 [1979] ["It has been noted ... that the rule justifying the ** devaluation of minority shares in closely held corporations for their lack of control has little validity when the shares are to be purchased by someone who is already”
6 later decisions quote this exact passage · from the majority“if costs are incurred after effectuation of the [triggering event], those costs should not be assessed against the dissenting shareholders.”
2 later decisions quote this exact passage · from the majority“[O]rdinarily when dissenting stock is accorded net asset value, that value is to be determined by considering the corporation as a going concern and not as if it is undergoing liquidation.”
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.