Wuchter v. Pizzutti’s Empirical Analysis
276 U.S. 13 · 1928
Citation profile
152 federal appellate · 86 district · 422 state decisions
How this case has been cited
Cited by 879 later decisions (42 by the Supreme Court) — most recently June 2023 · most notably International Shoe Co. v. Washington (1945), Mullane v. Central Hanover Bank & Trust Co. (1950)
152 federal appellate · 86 district · 422 state decisions — followed in 42 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 · Slaughter-House Cases the Butchers' Benevolent Association of New Orleans v. The Crescent City Live · Hess v. Pawloski · Albert Twining v. State of New Jersey · 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 879 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he enforced acceptance of the service of process on a state officer by the defendant would not be fair or due process unless such officer or the plaintiff is required to mail the notice to the defendant, or to advise him, by some written communication, so as to make it reasonably probable that he will receive actual notice. Otherwise, where the service of summons is limited to a service on the Secretary of State or some officer of the state, without more, it will be entirely possible for a person injured to sue any non-resident he chooses, and through service upon the state official obtain a default judgment against a non-resident who has never been in the state, who had nothing to do with the accident, or whose automobile having been in the state has never injured anybody. A provision of law for service that leaves open such a clear opportunity for the commission of fraud ... or injustice is not a reasonable provision, and in the case supposed would certainly be depriving a defendant of his property without due process of law.”
7 later decisions quote this exact passage · from the majoritye.g. State v. Verdirome · Colley v. Dyer“(n)ot having been directed by the statute (actual notice via the Secretary's mailing) cannot, therefore, supply constitutional validity to the statute or to service under it.”
6 later decisions quote this exact passage · from the majority““ * * * the state may properly authorize service to be made on one of its own officials, if it also requires that notice of that service shall be communicated to the person sued. Every statute of this kind * * * should impose * * * upon the official receiving service * * * the duty of communication by mail or otherwise with the defendant.” (Emphasis supplied.)”
5 later decisions quote this exact passage · from the majoritye.g. Jones v. Paxton · Combs v. Chambers
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.