Alexander Magruder v. Samuel a Drury’s Empirical Analysis
235 U.S. 106 · 1914
Citation profile
77 federal appellate · 13 district · 108 state decisions
How this case has been cited
Cited by 320 later decisions (23 by the Supreme Court) — most recently June 2020 · most notably Securities and Exchange Commission v. Chenery Corporation (1943), Garrett v. Co (1942)
77 federal appellate · 13 district · 108 state decisions — followed in 22 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
reviewedthe decision below (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on Gila Valley Globe Northern Railway Company v. John Hall · Antoine Michoud v. Peronne Bernardine Girod · United States v. Carter · Montana Railway Co. v. Warren
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 320 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘It is a well-settled rule that a trustee can make no profit out of his trust. The rule in such cases springs from his duty to protect the interests of the estate, and not to permit his personal interest to in any wise conflict with his duty in that respect. The intention is to provide against any possible selfish interest exercising an influence which .can interfere with the faithful discharge of the duty which is owing in a fiduciary capacity.’ Magruder v. Drury, 235 U.S. 106 , 35 S. Ct. 77,82 , 59 L.Ed. 151,156 .””
7 later decisions quote this exact passage · from the majority““It makes no difference that the estate was not a losei' in the transaction, or that the commission was no more than the services were reasonably worth. It is the relation of the trustee to the estate which prevents his dealing in such way as to make a personal profit for himself.””
2 later decisions quote this exact passage · from the majority““As to this allowance, the auditor made a lengthy finding of fact, setting forth in detail the services rendered by the trustees over a period of ten years, finding, as to the character of the estate, that the great bulk thereof was second trust notes of small amounts, as to which the auditor says that the transactions were almost innumerable, the total number of notes approximating 3,000, and ho sets forth in detail other services involving care of the real estate, looking after the repairs of the property, acquiring parcels of real estate, and the sale thereof, and saying in conclusion that he had no hesitancy in finding that the trustees were well entitled to the commissions allowed.””
1 later decision quote this exact passage · from the majoritye.g. Caldwell v. Hopkins
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.