In Re White’s Empirical Analysis
1967
Citation profile
14
cited by 14 later decisions
3
states following
September 1981
most recently cited
2 federal appellate · 1 district · 5 state decisions
Relationships
Relies on Bird v. United States
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"The opening language of subsection (4) indicates an intent to provide that where a security interest in personal property is perfected by indication of same upon a certificate of title as required by statute of another jurisdiction, the provisions of subsection (3) are not applicable. These circumstances or background facts exist here. Since it is stipulated that the security lien was properly perfected under the laws of Virginia, any further attack upon such perfection in any jurisdiction must be based upon the law of that State. No such attack is made here and the filing provisions of subsection (3) are not applicable. Unless construed as above subsection (4) would have little or no meaning. `There is a presumption against a construction which would render a statute ineffective or inefficient * * *.' Bird v. United States, 187 U.S. 118, at 124 [ 23 S.Ct. 42, 44 , 47 L.Ed. 100 ]."”
3 later decisions quote this exact passage · from the majority“[i]f personal property is covered by a certificate of title issued under a statute of . . . any other jurisdiction which requires indication on a certificate of title of any security interest in the property as a condition of perfection, then the perfection is governed by the law of the jurisdiction which issued the certificate. (emphasis added)”
2 later decisions quote this exact passage · from the majority““3. * * * [§ 8.9-302(3)] should be consulted for certain transactions as to which the filing provisions of this Article do not apply. Where property is covered by a certificate of title, the governing rule is stated in subsection (4) [§ 8.9-103(4)] of this section.” ****** “7. Collateral other than accounts, contract rights, general intangibles, and mobile equipment [§ 8.9-103(2)] may be brought into this state subject to a security interest which has attached and may have been perfected under the laws of another jurisdiction. If the property is covered by a certificate of title, subsection (4) [§ 8.9-103(4)1 applies.” (Italics added)”
1 later decision quote this exact passage · from the majoritye.g. In Re Smith
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.