Studley v. Boylston National Bank’s Empirical Analysis
229 U.S. 523 · 1913
Citation profile
221 federal appellate · 105 district · 81 state decisions
How this case has been cited
Cited by 779 later decisions (11 by the Supreme Court) — most recently March 2025 · most notably Citizens Bank of Md. v. Strumpf (1995), Wayne United Gas Co. v. Owens-Illinois Glass Co. (1937)
221 federal appellate · 105 district · 81 state decisions — followed in 20 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
reviewedStudley v. Boylston Nat. Bank of Boston (from First Circuit Court of Appeals)
Relationships
Relies on New York County National Bank v. Massey · Harrington v. Atlantic & Pacific Telegraph Co. · Studley v. Boylston Nat. Bank of Boston
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 779 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the absurdity of making A pay B when B owes A.”
30 later decisions quote this exact passage · from the majority““a. Tn all cases of mutual debts or mutual credits between the estate of a bankrupt and a creditor the, account shall be stated and one debt shall be set off against the other, and the balance only shall he allowed or paid. “b. A set-off or counterclaim shall not ho allowed in favor of any debtor of the bankrupt which (1) is not provable against the estate: or (2) was purchased by or transferred to him after the filing of the petition, or within four months before such filing, with a view to such use and with knowledge of notice that such bankrupt was insolvent, or had committed an act of bankruptcy.” Comp. St. § 9852.”
6 later decisions quote this exact passage · from the majority““The money so deposited was the proceeds of the sale of tickets to a large party of round-the-world tourists, and was put in bank, not for the purpose of preferring it, but in the expectation of being used for carrying on the business in the future as in the past. Indeed, the payments were made with the statement that the company would expect the bank to discount other notes. We find nothing in the record to indicate that the deposits were made for the purpose of enabling the bank to secure a preference by the exercise of the right of set-off. The ease, therefore, comes directly within the decision in New York County Nat. Bank v. Massey, 192 U. S. 138 , 24 S. Ct. 199 , 48 L. Ed. 380 , where $3,884 deposited by an insolvent customer, in good faith, four days before the filing of the petition against him, was allowed to the bank by way of seUoff on notes of the bankrupt held by it.””
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.