Leonard v. Counts’s Empirical Analysis
1980
Citation profile
5 federal appellate · 2 district · 80 state decisions
How this case has been cited
Cited by 135 later decisions — most recently August 2016 · most notably Nedrich v. Jones (1993), 3 Va. App. 337 - Woolley v. Woolley (1986)
5 federal appellate · 2 district · 80 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.
Relationships
Relies on Horne v. Holley · Salyer v. Salyer · Peal v. Luther · Kellow v. Bumgardner · Sutton v. Sutton
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 135 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Constructive trusts arise, independently of the intention of the parties, by construction of law, being fastened upon the conscience of him who has the legal estate, in order to prevent what otherwise would be a fraud. They occur not only where property has been acquired by fraud or improper means, but also where it has been fairly and properly acquired, but it is contrary to the principles of equity that it should be retained, at least for the acquirer’s own benefit.”
16 later decisions quote this exact passage · from the majority“[a]n express trust is based on the declared intention of the trustor,”
2 later decisions quote this exact passage · from the majority“[A] resulting trust arises when one person pays for property, or assumes payment of all or part of the purchase money, but has title conveyed to another with no mention of a trust in the conveyance .... Although a subsequent payment of, or promise to pay, the purchase price will not create a resulting trust, such a trust arises when prior to the purchase one person binds himself to pay purchase money and stands behind his commitment, but title is conveyed to another.”
1 later decision quote this exact passage · from the majoritye.g. Gibbens v. Hardin
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.