Northern Pacific Railway Co. v. Boyd’s Empirical Analysis
228 U.S. 482 · 1913
Citation profile
366 federal appellate · 102 district · 80 state decisions
How this case has been cited
Cited by 1,064 later decisions (72 by the Supreme Court) — most recently October 2018 · most notably Norwest Bank Worthington v. Ahlers (1988), Case v. Los Angeles Lumber Products Co. (1939)
366 federal appellate · 102 district · 80 state decisions — followed in 26 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
reviewedNorthern Pac. Ry. Co. v. Boyd (from Ninth Circuit Court of Appeals)
Relationships
Relies on Scott v. Neely · Fauntleroy v. Lum · Hollins v. Brierfield Coal & Iron Co. · Dickerman v. Northern Trust Co.
Cited together with Case v. Los Angeles Lumber Products Co. · Consolidated Rock Products Co. v. Du Bois · Norwest Bank Worthington v. Ahlers · Louisville Trust Co v. Louisville N a C Ry Co · Group of Institutional Investors v. Chicago, Milwaukee, St. Paul & Pacific Railroad
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 1,064 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“present or prospective, for dividends or only for purposes of control”
23 later decisions quote this exact passage · from the majority““Corporations, insolvent or financially embarrassed, often find it necessary to scale their debts and readjust stock issues with an agreement to conduct the same business with the same property under a reorganization. This may be done in pursuance of a private contract between bondholders and stockholders. And though the corporate property is thereby transferred to a new company, having the same shareholders, the transaction would be binding between the parties. But, of course, such a transfer by stockholders from themselves to themselves cannot defeat the claim of a nonassenting creditor. As against him the sale is void in equity, regardless of the motive with which it was made. For if such contract reorganization was consummated in good faith and in ignorance of the existence of the creditor, yet when he appeared and established his debt, the subordinate interest of the old stockholders would still be subject to his claim in the hands of the reorganized company. * * * There is no difference in principle if the contract reorganization, instead of being effectuated by private sale, is consummated by a master’s deed under a consent decree. * * * “For, if purposely or unintentionally a single creditor was not paid, or provided for in the reorganization, he could assert his superior rights against the subordinate interests of the old stockholders in the property transferred to the new company. They were in the position of insolvent debtors who could not reserve an interest as ag”
10 later decisions quote this exact passage · from the majority“[T]he stockholder’s interest in the property is subordinate to the rights of creditors; first of secured and then of unsecured creditors.... [A]ny arrangement of the parties by which the subordinate rights and interests of stockholders are attempted to be secured at the expense of the prior rights of either class of creditors comes within judicial denunciation.”
4 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.