Smith v. Leonard’s Empirical Analysis
1994
Citation profile
20 state decisions
How this case has been cited
Cited by 20 later decisions — most recently September 2011
20 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 In Re the Judicial Dissolution of Kemp & Beatley, Inc. · Gries Sports Enterprises, Inc. v. Cleveland Browns Football Co. · Conway Corp. v. Construction Engineers, Inc. · Firstbank of Arkansas v. Keeling · Andersen v. Albert & J. M. Anderson Manufacturing Co.
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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Defining oppressive conduct as distinct from illegality in the present context has been considered in other forums. The question has been resolved by considering oppressive actions to refer to conduct that substantially defeats the ‘reasonable expectations’ held by minority shareholders in committing their capital to the particular enterprise. A shareholder who reasonably expected that ownership in the corporation would entitle him or her to a job, a share of corporate earnings, a place in corporate management, or some other form of security, would be oppressed in a very real sense when others in the corporation seek to defeat those expectations and there exists no effective means of salvaging the investment. A court considering a petition alleging oppressive conduct must investigate what the majority shareholders knew, or should have known, to be the petitioner’s expectations in entering the particular enterprise. Majority conduct should not be deemed oppressive simply because the petitioner’s subjective hopes and desires in joining the venture are not fulfilled. Disappointment alone should not necessarily be equated with oppression.”
1 later decision quote this exact passagee.g. Landstrom v. Shaver“A. A director shall discharge his duties as a director, including his duties as a member of a committee: 1. In good faith; 2. With the care an ordinarily prudent person in a like position would exercise under similar circumstances; and 3. In a manner he reasonably believes to be in the best interest of the corporation.”
1 later decision quote this exact passagee.g. Long v. Lampton
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.