Steele v. Drummond’s Empirical Analysis
275 U.S. 199 · 1927
Citation profile
64 federal appellate · 17 district · 50 state decisions
How this case has been cited
Cited by 211 later decisions (34 by the Supreme Court) — most recently October 2018 · most notably Muschany v. United States (1945), Helvering v. Tex-Penn Oil Co. (1937)
64 federal appellate · 17 district · 50 state decisions — followed in 14 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
reviewedDrummond v. Steele (from Fifth Circuit Court of Appeals)
Relationships
Relies on Oscanyan v. Arms Co. · Baltimore & Ohio Southwestern Railway Co. v. Voigt · Trist v. Child · Alexander Marshall v. The Baltimore and Ohio Railroad Company · Webster Electric Co. v. Splitdorf Electrical Co.
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 211 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““And it is a matter of great public concern that freedom of contract be not lightly interfered with. * * * It is only in clear cases that contracts will be held void. * * * Detriment to the public interest will not be presumed, where nothing sinister or improper is done or contemplated. * * * “The claims there considered” (referring to a list of cases including the Oscanyan case) “were under contracts requiring or contemplating the obtaining of legislative or executive action as a matter of favor by means of personal influence, solicitation, and the like, or by other improper or corrupt means.””
6 later decisions quote this exact passage · from the majority“It is an undoubted principle of the common law, that it will not lend its aid to enforce a contract to do an act that is illegal; or which is inconsistent with sound morals or public policy; or which tends to corrupt or contaminate, by improper influences, the integrity of our social or political institutions.”
1 later decision quote this exact passage · from the majoritye.g. Meuse v. Henry
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.