First National Bank v. Staake’s Empirical Analysis
202 U.S. 141 · 1906
Citation profile
67 federal appellate · 34 district · 15 state decisions
How this case has been cited
Cited by 183 later decisions (15 by the Supreme Court) — most recently September 2002 · most notably Bank of Marin v. England (1966), Taubel-Scott-Kitzmiller Co. v. Fox (1924)
67 federal appellate · 34 district · 15 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.
Appellate journey
reviewedReceivers of Virginia Iron v. Staake (from Fourth Circuit Court of Appeals)
Relationships
Relies on Hewit v. Berlin Machine Works · Receivers of Virginia Iron v. Staake · In re Baird
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 183 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]hat all ... liens obtained through legal proceedings against a person who is insolvent, at any time within four months prior to the filing of a petition in bankruptcy against him, shall be deemed null and void in case he is adjudged a bankrupt, and the property affected by the ... lien shall be deemed wholly discharged and released from the same, and shall pass to the trustee as a part of the estate of the bankrupt, unless the court shall ... order that the right under such ... lien shall be preserved for the benefit of the estate; and thereupon the same may pass to and shall be preserved by the trustee for the benefit of the estate as aforesaid.”
4 later decisions quote this exact passage · from the majority““The rule that the trustee takes the estate of the bankrupt in the same plight as the bankrupt held it is not api>licable to liens which, although valid as to the bankrupt, are invalid as to creditors.””
4 later decisions quote this exact passage · from the majoritye.g. In re Cramond · In re Hickerson““In our opinion the conclusion to be drawn from this language is that it is the lien created by a levy or a judgment, or an attachment, or otherwise, that is invalidated, and that, where the lien is obtained more than four months prior to the filing of the petition, it is not only not to be deemed to be null and void on adjudication, but its validity is recognized. When it is obtained within four months the property is discharged therefrom, but not otherwise. A judgment or decree in enforcement of an otherwise valid preexisting lien is not the judgment denounced by the statute, which is plainly confined to judgments creating liens. If this were not so, the date of the acquisition of a lien by attachment or creditors’ bill would be entirely immaterial.””
2 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.