4 Wash. App. 52 - Harrison v. Puga’s Empirical Analysis
1971
Citation profile
3 federal appellate · 1 district · 33 state decisions
How this case has been cited
Cited by 40 later decisions — most recently March 1995 · most notably Dewitt Truck Brokers, Inc. v. W. Ray Flemming Fruit Co. (1976), Henderson v. Buchanan (In Re Western World Funding, Inc.) (1985)
3 federal appellate · 1 district · 33 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 International Shoe Co. v. Washington · Hanson v. Denckla · 54 Wash. 2d 570 - Thorndike v. Hesperian Orchards, Inc. · 62 Wash. 2d 106 - Tyee Construction Co. v. Dulien Steel Products, Inc. · 69 Wash. 2d 392 - Kueckelhan v. Federal Old Line Insurance
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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"While the facts of each case, in which the doctrine of disregarding the corporate entity is applied, vary, there is one situation common to all: a right owned and its corresponding duty owed to the person demanding recognition of his right and the performance of its corresponding duty. For example, the obligee of a contract has a right to receive performance of its obligations. The obligor, on the other hand, is under a corresponding duty to perform those obligations. When the doctrine of disregard is applied, it is applied because of the necessity of enforcing this right-duty. . . . When expressed it has usually been expressed in a restricted form, namely, by a holding that before a corporate entity is disregarded, some species of fraud, bad faith or other wrong must exist to be obviated . . . But such cases often mean nothing more than that violation of duty (denoted as fraud) will result if the entity be not disregarded. . . . The enforcement of the duty owed requiring it, the courts disregarded the corporate entity by refusing to give effect to the claimed incident of corporate status."”
2 later decisions quote this exact passage“when a corporate stockholder himself ... disregards the separate entity of the corporation to the prejudice of [creditors], he can scarcely complain if the Court judges him by his conduct and likewise disregards the corporate entity in order to enforce [those creditors’ rights].”
2 later decisions quote this exact passage“[W]hen only the rights of plaintiff and defendant are to be determined, there being no innocent third party rights involved, then, notwithstanding that plaintiff's rights are initially against a corporation, the corporate entity may likewise be disregarded as a matter of convenience, e.g., to avoid circuitous action. Whether or not the defendant's overt intent was to disregard the corporate entity may be, but is not necessarily involved.”
1 later decision 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.