Early v. Richardson’s Empirical Analysis
280 U.S. 496 · 1930
Citation profile
79 federal appellate · 15 district · 60 state decisions
How this case has been cited
Cited by 190 later decisions (13 by the Supreme Court) — most recently May 2000 · most notably Anderson v. Abbott (1944), Forrest v. Jack (1935)
79 federal appellate · 15 district · 60 state decisions — followed in 19 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
reviewedthe decision below (from Fourth Circuit Court of Appeals)
Relationships
Relies on Keyser v. Hitz · Ohio Valley National Bank v. John Hulitt · Johnston v. Laflin · Houghton v. Hubbell
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 190 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ 'Is one, who purchases shares of stock of a national bank, liable for an assessment subsequently imposed by the comptroller of the currency upon the stock for the benefit of the creditors of the bank after the insolvency thereof, when it appears that the purchaser bought the stock from the registered holder thereof and received a certificate therefor endorsed in blank by the holder, with intent at the time of such purchase and delivery of giving the stock to his minor child, but without knowledge at that time of the failing condition of the bank, or intent to avoid the stockholder’s liability, and when, after the acceptance of the endorsed certificate from the seller, and before the insolvency, the purchaser with like knowledge and intent, promptly presents the certificate to the bank, causes the shares to be registered and a new certificate to be issued in the child’s name?’ . . . “The real question is whether the intent of Richardson to buy the stock for his minor children, and the fact that by his direction the transfer was made to them upon the books of the bank and certificates issued in their names, had the effect of relieving Richardson from liability. We think not, since the transferees, being minors, were without legal capacity to assume the obligation. Upon coming of age they would have an election either to affirm or avoid the entire transaction. In the meantime, the transfer of the stock having resulted to their disadvantage, the law will avoid it for them, thus”
2 later decisions quote this exact passage · from the majority““The real question is whether the intent of Richardson to buy the stock for his minor children, and the fact that by his direction the transfer was made to them upon the books of the bank and certificates issued in their names, had the effect of relieving Richardson from liability. We think not, since the transferees, being minors, were without legal capacity to assume the obligation. Upon coming-of age they would have an election either to affirm or avoid the entire transaction. In the meantime, the transfer of the stock having resulted to their disadvantage, the law will avoid it for them, thus leaving the liability of Richardson for assessments unaffected. See Aldrich v. Bingham [D. C.] 131 F. 363 ; Foster v. Chase (Foster v. Wilson) [C. C.] 75 F. 797 .” Page 499 of 280 U. S., 50 S. Ct. 176.”
1 later decision quote this exact passage · from the majoritye.g. Slaughter v. Quigley
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.