Ringer v. Lockhart’s Empirical Analysis
1977
Citation profile
3 federal appellate · 32 state decisions
How this case has been cited
Cited by 37 later decisions — most recently June 2019 · most notably Wilson v. S & L Acquisition Co., L.P. (1991), 153 Ga. App. 636 - Morton v. Stewart (1980)
3 federal appellate · 32 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 Tilley v. King · 120 Ga. App. 420 - Southern Bell Telephone & Telegraph Co. v. Beaver · Dorsey v. Green · Clark v. Clark · 129 Ga. App. 718 - Giant Peanut Co. v. Carolina Chemicals, Inc.
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If one of the interests involved is that of the trustee personally, selfishness is apt to lead her to give herself an advantage[,] ... it is not necessary for the beneficiaries to show that the trustee acted in bad faith, gained an advantage, or that they were harmed. The trustee must avoid being placed in such a position, and if she cannot avoid it, she may resign, may fully inform the beneficiaries of the conflict, or may request the court to appoint a guardian ad litem to protect the unprotected interests.”
1 later decision quote this exact passage · from the majority“The broad rule of equity ... is that it is the duty of a trustee not to ... do any act inconsistent with the interest of the beneficiary .... Whenever he has placed himself in a position that his personal interest has or may come in conflict with his duties as trustee, a court of equity never hesitates to remove him. In such circumstances the court does not stop to inquire whether the transactions complained of were fair or unfair; the inquiry stops when such relation is disclosed.”
1 later decision quote this exact passage · from the majority“Fraud may be consummated by signs or tricks, acts or silence, concealment when there is a duty to disclose, or by any other unfair way used to cheat another. Code Ann. §§ 37-705 and 105-304.”
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.