Beadle v. Daniels’s Empirical Analysis
1961
Citation profile
4 federal appellate · 8 state decisions
How this case has been cited
Cited by 12 later decisions — most recently August 2000
4 federal appellate · 8 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 Hansberry v. Lee · United Mine Workers of America v. Benedict Coal Corporation · Antoine Michoud v. Peronne Bernardine Girod · Alexander Magruder v. Samuel a Drury · Chicago St Ry Co v. Des Moines Union Ry Co Des Moines Union Ry 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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It has been held that the judgment in the ‘spurious’ type class of action is not binding as in the ‘true’ class action, upon the entire class. It binds only those actually before the court. If parties voluntarily come in as inter-veners under the plaintiff’s complaint, they would be bound under the rules of res judicata, but if such parties refuse or neglect to enter the suit, preferring to institute their separate suits, the judgment cannot be held to bind them. [Citations omitted.] “Since this case relates to the enforcement of rights which are several but grow out of common questions of law and fact, it is a spurious class action and the doctrine of res judicata will apply only to those who are before the court. Apparently both the present plaintiff and defendants know the names and perhaps the whereabouts of those persons who were interest holders at the time of the transaction complained of, and also what assignments of interest have been made since that time. It would therefore have been proper if the trial court at an appropriate time, perhaps at pretrial conference, had made inquiry and thereafter caused proper notice to be given to all of the real parties in interest. This omission is not irremediable and notice should now be given. Those interest holders who express a desire to intervene should be allowed to do so during a time and under circumstances which the trial court deems to be reasonable.””
1 later decision quote this exact passage · from the majority“"* * * Other facts and circumstances must be shown before the rule can operate as an estoppel. Unless the delay has worked injury, prejudice or disadvantage to the defendants or others adversely interested, it is not of itself laches. * * *" Beadle v. Daniels, Wyo., 362 P.2d 128, 131 (1961), and authorities cited therein.”
1 later decision quote this exact passage · from the majoritye.g. Hartnett v. Jones
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.