Lockhart v. Van Alstyne’s Empirical Analysis

Citation profile

9 federal appellate · 1 district · 33 state decisions

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 51 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““ The statute which the plaintiff relies upon is section 1821 of Comp, Laws of 1857, which, on the neglect or re fusal of tne directors of manufacturing companies to comply with certain provisions of law regarding the filing of their articles of association, and of annual reports showing their financial condition, declares that such directors ‘ shall be jointly and severally liable in an action founded on this statute, for all the debts of such corporation contracted during the period of such neglect or refusal.’ This statute, it will be perceived, only makes the directors personally liable for ‘debts.* Liabilities of a company which may give causes of action against it and result in judgments are not within the statute unless they constitute present debts. A debt is that which one person is bound to pay to another, either presently or at some future period; something which may be the subject of a suit as a debt, and not something to which the party may be entitled as damages in consequence of a failure to perform a duty or keep an engagement. A right to a dividend from the profits of a corporation is no debt until the dividend is declared.””

   2 later decisions quote this exact passage
   e.g. Weber v. Draper · Soberg v. Sanders