Ontjes v. MacNider’s Empirical Analysis
1942
Citation profile
8 state decisions
How this case has been cited
Cited by 8 later decisions — most recently July 1994
8 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 Meinhard v. Salmon · Beatty v. . Guggenheim Exploration Co. · Guth v. Loft, Inc. · Wendt v. Fischer · Bailey v. Jacobs
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] finding of “corporate opportunity” will be denied (a) wherever the fundamental fact of good faith is determined in favor of the director or officer charged with usurping the corporate opportunity, or (b) where the company is unable to avail itself of the opportunity, or (c) where availing itself of the opportunity is not essential to the company’s business, or (d) where the accused fiduciary does not exploit the opportunity by the employment of his company’s resources, or (e) where by embracing the opportunity personally the director or officer is not brought into direct competition with his company and its business. It will be observed that all of the foregoing elements are stated disjunctively and it would therefore seem that the absence of any one of them is sufficient to defeat such claim of corporate opportunity as is made in this case.”
2 later decisions quote this exact passagee.g. Sauer v. Moffitt · Connolly v. Bain“if there is presented to a corporate officer or director a business opportunity which the corporation is financially able to undertake, [2] is, from its nature, in the line of the corporation’s business and is of practical advantage to it, [3] is one in which the corporation has an interest or a reasonable expectancy, and by embracing the opportunity, the self-interest of the officer or director will be brought into conflict with that of his corporation, the law will not permit him to seize the opportunity for himself.”
2 later decisions quote this exact passagee.g. Sauer v. Moffitt · Lange v. Lange
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.