Baltimore Co v. Phillips’s Empirical Analysis
274 U.S. 316 · 1927
Citation profile
609 federal appellate · 177 district · 230 state decisions
How this case has been cited
Cited by 1,609 later decisions (81 by the Supreme Court) — most recently February 2019 · most notably United Mine Workers of America v. Gibbs (1966), Federated Department Stores, Inc. v. Moitie (1981)
609 federal appellate · 177 district · 230 state decisions — followed in 32 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
reviewedBaltimore S. S. Co. v. Phillips (from Second Circuit Court of Appeals)
Relationships
Relies on Cromwell v. County of Sac · The Osceola · Panama Co v. Johnson · Engel v. Davenport
Cited together with Hurn v. Oursler · Pacific Co v. Peterson · American Fire & Casualty Co. v. Finn · Cromwell v. County of Sac · Panama Co v. Johnson
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 1,609 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A cause of action does not consist of facts, but of the unlawful violation of a right which the facts show. The number and variety of the facts alleged do not establish more than one cause of action so long as their result, whether they be considered severally or in combination, is the violation of but one right by a single legal wrong.””
45 later decisions quote this exact passage · from the majority“The effect of a judgment or decree as res judicata depends upon whether the second action or suit is upon the same or a different cause of action. If upon the same cause of action, the judgment or decree upon the merits in the first case is an absolute bar to the subsequent action or suit between the same parties or those in privity with them, not only in respect of every matter which was actually offered and received to sustain the demand, but also as to every ground of recovery which might have been presented. * * * 6 * * * * * * 7”
31 later decisions quote this exact passage · from the majority“[a] judgment merely voidable because based upon an erroneous view of the law is not open to collateral attack, but can be corrected only by a direct review and not by bringing another action upon the same cause [of action].”
8 later decisions 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.