Pennington v. Fourth National Bank of Cincinnati’s Empirical Analysis
243 U.S. 269 · 1917
Citation profile
71 federal appellate · 5 district · 133 state decisions
How this case has been cited
Cited by 277 later decisions (22 by the Supreme Court) — most recently October 2010 · most notably Shaffer v. Heitner (1977), Propper v. Clark (1949)
71 federal appellate · 5 district · 133 state decisions — followed in 28 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.
Relationships
Relies on Pennoyer v. Neff · Harris v. Balk · Chicago Ry Co v. Sturm · Freeman v. Alderson
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 277 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“immaterial that the claim is, at the commencement of the suit, inchoate, to be perfected only by time or the action of the court”
4 later decisions quote this exact passage · from the majority“"The Fourteenth Amendment did not, in guaranteeing due process of law, abridge the jurisdiction which a State possessed over property within its borders, regardless of the residence or presence of the owner. That jurisdiction extends alike to tangible and to intangible property. Indebtedness due from a resident to a non-resident of which bank deposits are an example is property within the State. Chicago, Rock Island & Pacific Ry. Co. v. Sturm, 174 U.S. 710 , 19 S.Ct. 797 , 43 L.Ed. 1144 . It is, indeed, the species of property which courts of the several States have most frequently applied in satisfaction of the obligations of absent debtors. Harris v. Balk, 198 U.S. 215 , 25 S.Ct. 625 , 49 L.Ed. 1023 .... [G]arnishment or foreign attachment is a proceeding quasi in rem. Freeman v. Alderson, 119 U.S. 185, 187 , 7 S.Ct. 165 , 30 L.Ed. 372, 373 . The thing belonging to the absent defendant is seized and applied to the satisfaction of his obligation. The Federal Constitution presents no obstacle to the full exercise of this power."”
1 later decision quote this exact passage · from the majority“The only essentials to the exercise *Page 384 of the State's power are the presence of the res within its borders, its seizure at the commencement of the proceedings and the opportunity of the owner to be heard. Where such essentials exist, a decree for alimony against an absent defendant will be valid under the same circumstances and to the same extent as if the judgment were on a debt — that is — it will be valid not in personam, but as a charge to be satisfied out of the property seized.”
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.