Commonwealth v. Yarnell’s Empirical Analysis
1933
Citation profile
2 federal appellate · 29 state decisions
How this case has been cited
Cited by 35 later decisions — most recently January 1980 · most notably Commonwealth Ex Rel. Esenwein v. Esenwein (1943), Goodloe v. Hawk (1940)
2 federal appellate · 29 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 Hilton v. Guyot · John Haddock v. Harriet Haddock · Annie Andrews v. Kate H Andrews · German Savings Loan Society v. Dora May Dormitzer L B · Adams v. Adams
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is true that a foreign divorce may be attacked collaterally by the defendant spouse where his or her rights are involved. It may also be attacked by persons claiming under the defendant spouse. The right to impeach collaterally a decree of divorce made in another state by showing fraud or want of jurisdiction has been frequently recognized. See German Savings & Loan Society v. Dormitzer, 192 U.S. 125, 128 ; Andrews v. Andrews, 188 U.S. 14, 39 ; 19 C.J., page 375, sections 844, 845; Rex v. Brinkley, 14 Ont. L.R. 434, and Rex v. Lolley, 168 English Reports 779. Third persons whose rights are concerned may under certain circumstances attack a divorce collaterally. See Adams v. Adams, 154 Mass. 290 , 28 N.E. 260 , and Hollingshead v. Hollingshead (N.J.), 110 Atl. Rep. 19 , syllabus 3. “However, in order to invalidate the Mexican divorce decree it would have to be shown not only that the then respondent (the first Mrs. Yamell) was not in Mexico at the time of the proceedings but that she was never properly served with process, was not represented by counsel, and that the cause of action did not arise in the foreign jurisdiction. See Grossman’s Est. (No. 1), 263 Pa. 139 , 106 A. 86 ; Duncan v. Duncan, 265 Pa. 464 , 109 A. 220 , and Haddock v. Haddock, 201 U.S. 562 .””
2 later decisions quote this exact passage
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.