37 Md. App. 413 - Lynch v. Buchanan’s Empirical Analysis
1977
Citation profile
1 federal appellate · 2 district · 4 state decisions
How this case has been cited
Cited by 11 later decisions — most recently March 2002
1 federal appellate · 2 district · 4 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 East Washington Railway Co. v. Brooke · Indurated Concrete Corp. v. Abbott · Murray-Baumgartner Surgical Instrument Co. v. Requardt · Williams v. Salisbury Ice Co. · Chesapeake Construction Corp. v. Rodman
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Nothing connected with the normal internal disputes between the shareholders is to be made the subject of a bill by some one shareholder in behalf of himself and others, unless there be something illegal, oppressive or fraudulent--unless there is something ultra vires on the part of the company, qua company, or on the part of the majority of the company, so that they are not fit persons to determine it.”
2 later decisions quote this exact passage · from the majority“[WJhere directors or shareholders act in such a way to use their positions to advance their own individual interests as distinguished from that of the corporation or acquire interests] that may conflict with the clear and proper discharge of their duties that transaction is not ipso facto void but conversely it is not necessary to establish that there has been actual fraud practiced by the party holding the confidential or fiduciary relationship. The proof is upon that director or shareholder once it is shown that he has dealt in a way to perform his own interest to show the fairness and adequacy of the transaction. In other words, the burden of going forward shifts.”
1 later decision quote this exact passage · from the majority“[t]he acts of the directors or those in control of the corporation are illegal, oppressive, or fraudulent.”
1 later decision quote this exact passage · from the majoritye.g. Everett v. I-Net Inc
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.