German Alliance Insurance Company v. Home Water Supply Company’s Empirical Analysis
226 U.S. 220 · 1912
Citation profile
105 federal appellate · 48 district · 114 state decisions
How this case has been cited
Cited by 491 later decisions (9 by the Supreme Court) — most recently March 2021 · most notably Robins Dry Dock & Repair Co. v. Flint (1927), H. R. Moch Co. v. Rensselaer Water Co. (1928)
105 federal appellate · 48 district · 114 state decisions — followed in 27 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.
Appellate journey
reviewedGerman Alliance Ins. v. Home Water Supply Co. (from Fourth Circuit Court of Appeals)
Relationships
Relies on Burgess v. Seligman · Baltimore Co v. Baugh · Savings Bank v. Ward · Hendrick v. Lindsay
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 491 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“it is recognized as an exception to the general principle, which proceeds on the legal and natural presumption that a contract is only intended for the benefit of those who made it. Before a stranger can avail himself of the exceptional privilege of suing for a breach of an agreement to which he is not a party, he must, at least, show that it was intended for his direct benefit.”
16 later decisions quote this exact passage · from the majority““From them [the many decisions upon the question] it appears that the majority of American courts hold that the taxpayer has no direct interest in such ageements, and therefore cannot sue ex contractu. Neither can he sue in tort, because, in the absence of a contract obligation to him, the water company owes him no duty for the breach of which he can maintain an action ex delicto.””
1 later decision quote this exact passage · from the majoritye.g. Baca v. Britt“"... the majority of American courts hold that the taxpayer has no direct interest in such agreements, and therefore cannot sue ex contractu. Neither can he sue in tort, because, in the absence of a contract obligation to him, the water company owes him no duty for the breach of which he can maintain an action ex delicto. "”
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.