Morrow v. Morrow’s Empirical Analysis
1919
Citation profile
12 state decisions
How this case has been cited
Cited by 12 later decisions — most recently September 1999
12 state decisions
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 Hudnall v. Ham · Bales v. Elder · Jenkins v. Drane · Elder v. Bales · Chambers v. Chambers
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“" This common law rule with reference to illegitimates remainded the law of this State until 1845, when the legislature abrogated the common law rule and provided that an illegitimate might inherit from its mother. Various other acts were enacted by subsequent legislatures extending the rights of illegitimates, until 1872, when the present Statute of Descent was passed. While, as counsel for the defendants in error contend, the statute conferring rights upon illegitimates is in derogation of the common law, still the' tendency of the legislation in this State upon this subject shows an intention upon the part of the legislature to remove the rigors of the common law and to establish a rule of descent with reference to illegitimates consonant with the finer sense of justice and right and not to visit the sins of the parents upon the unoffending offspring. . . . An illegitimate, therefore, as heir of his mother, would be entitled to inherit from her, in case of her death, in the same manner as her legitimate children. As heir of any maternal ancestor, and of any person from whom its mother might have inherited if living, a like position is occupied.””
1 later decision quote this exact passage · from the majority““The words ‘if living’ neither add to nor take from the clause under consideration. The meaning is plain that ‘ an illegitimate child shall be heir ... of any person from whom its mother might have inherited. ’ It is plain the mother could not inherit if she were not living, therefore the parenthetical expression ‘if living’ was inserted. We think the clear intention of the statute in question was to remove entirely the bar against illegitimates inheriting through the maternal line. ’ ’”
1 later decision quote this exact passage · from the majority““An illegitimate child shall be heir of its mother and any maternal ancestor, (and of any person from whom its mother might have inherited, if living).” (Parentheses supplied.)”
1 later decision 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.