Lamb v. Schmitt’s Empirical Analysis
285 U.S. 222 · 1932
Citation profile
73 federal appellate · 30 district · 120 state decisions
How this case has been cited
Cited by 320 later decisions (7 by the Supreme Court) — most recently June 2021 · most notably Lamb v. Cramer (1932), Long v. Ansell (1934)
73 federal appellate · 30 district · 120 state decisions — followed in 25 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
reviewedSchmitt v. Lamb (from Fifth Circuit Court of Appeals)
Relationships
Relies on Lewis v. Reynolds · Stewart v. Ramsay · Pacific Railroad of Missouri v. Missouri Pacific Ry. Co. And Others. 1 · Lamb v. Cramer
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 320 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“proceeds upon the ground that the due administration of justice requires that a court shall not permit interference with the progress of a cause pending before it, by the service of process in other suits, which would prevent, or the fear of which might tend to discourage, the voluntary attendance of those whose presence is necessary or convenient to the judicial administration in the pending litigation.”
20 later decisions quote this exact passage · from the majority““The test is whether the immunity itself, if allowed, would so obstruct judicial administration in the very cause for the protection of which it is invoked as to justify withholding it. That, as we have said, depends here upon the nature of the proceeding in which the service is made and its relation to the principal suit, both of which are disclosed by the pleadings.””
5 later decisions quote this exact passage · from the majority“Here the two suits, pending in the same court, are not independent of each other or unrelated. The second was brought in aid of the first, on which the petitioner, when served with process, was in attendance, charged with the duty of counsel in the case to assist the court. It was brought to secure rights asserted in the first suit which, but for the actions charged against the petitioner in the second, would have been secured in the first. The later suit was so much a part and continuation of the earlier one that the jurisdiction of the court over the first extended to the second without regard to citizenship of the parties or the satisfaction of any other jurisdictional requirements. From the viewpoint of the due administration of justice in the first suit, the second was as much a part of it as if it had been an interlocutory motion to compel the production in court of documents or of property involved in the suit. (Citations omitted.)”
1 later decision quote this exact passage · from the majoritye.g. Pointer v. Ghavam
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.