Warren v. White’s Empirical Analysis
1960
Citation profile
16 state decisions
How this case has been cited
Cited by 16 later decisions — most recently July 1985
16 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 Davis v. Patrick · Emerson v. Slater · Farmers Federation, Inc. v. . Morris · Meyers v. . Allsbrook · Peele v. Powell
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““No action shall be brought ... to charge any defendant upon a special promise to answer the debt, default or miscarriage of another person, unless the agreement upon which such action shall be brought, or some memorandum or note thereof, shall be in writing, and signed by the party charged therewith or some other person thereunto by him lawfully authorized.””
3 later decisions quote this exact passage“. . . [WJhenever the main purpose and object of the promisor is not to answer for another, but to subserve some pecuniary or business purpose of his own, involving either a benefit to himself, or damage to the other contracting party, his promise is not within the statute, although it may be in form a promise to pay the debt of another, and although the performance of it may incidentally have the effect of extinguishing that liability.”
2 later decisions quote this exact passage““As applied to promises by stockholders, officers, or directors, to pay a debt of the corporation, it may be said that the promise is original where the promisor’s primary object was to secure some direct and personal benefit from the performance by the promisee of his contract with the corporation, or from the latter’s refraining from exercising against the corporation some right existing in him by virtue of the contract. The benefit to the promisor is to be distinguished from the indirect benefit which would accrue to him merely by ¡virtue of his position as .a stockholder, officer, or director. If the benefit accruing is direct and personal, then the promise is original within the rule above discussed, and the validity thereof is not affected by the statute of frauds.” (Emphasis added.) Id. at 910 . “Where an oral promise by a stockholder,, officer, or director of a corporation is collateral in form and effect, and the consideration was not intended to secure or promote some personal object, or advantage of the promisor— as distinguished from the benefit accruing to a person from the mere fact of his being a stockholder, officer, or director — , the promise is collateral and within the statute of frauds.” Id. at 914 . . .”
1 later decision quote this exact passage
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.