Progress Laundry Company v. Hamilton’s Empirical Analysis
1925
Citation profile
21 state decisions
How this case has been cited
Cited by 21 later decisions — most recently October 1977
21 state decisions — followed in 10 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 Fulton Grand Laundry Co. v. Johnson · Berckhemer v. . Empire Carrying Corporation · Lewis v. Creasey Corp. · Morrison v. Woodbury · Stein v. National Life Ass'n
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Strangely enough, as it appears to us, some of the American courts have so adjudged, while a larger number, according to our opinion, correctly hold to the contrary. The text in 22 Cyc. 842, in an effort to concretely define the term ‘trade secret,’ says: ‘A trade secret is a plan or process, tool, mechanism or compound, known only to its owner and those of his employees to whom it is necessary to confide it. ... A process commonly known to the trade is not a trade secret and will not be protected by injunction. ’ That definition meets with our approval ... to hold that a list of customers, obtained in the manner as did defendant in this case, could not be solicited by bim . . . when subsequently engaged in a rival competing business is, according to our opinion, directly antagonistic to another cherished principle of law, i. e., that competition should not be stifled, but be free and untrammeled. If defendant . . . could be enjoined from soliciting his former customers ... in the prosecution of the same business for his new employer, then a traveling salesman, who is ordinarily called a ‘drummer,’ for a particular business . . . could not engage in business thereafter for another . . . conducting a like business ... by selling to his former customers. The inevitable result of which would be that a salesman would be forever barred from selling to a customer whose acquaintance he formed during his first employment.””
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.