Jacobs v. Northeastern Corp.’s Empirical Analysis
1965
Citation profile
12 federal appellate · 4 district · 52 state decisions
How this case has been cited
Cited by 107 later decisions — most recently August 2013 · most notably Ram Construction Company Inc v. American States Insurance Company American States Insurance Company (1984), National Shawmut Bank v. New Amsterdam Casualty Co. (1969)
12 federal appellate · 4 district · 52 state decisions — followed in 16 states
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 Pearlman v. Reliance Insurance · Prairie State Nat Bank of Chicago v. United States · Martin v. National Surety Co. · Memphis & Little Rock Railroad v. Dow · Memphis v.
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 107 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“None of the purposes or objectives of the Code's filing requirements would be served by holding that the subrogation to the contract balance now due is an assertion of a 'security interest' and therefore subject to the filing provisions of Article 9. The contract balance withheld would never have become due and payable * * * as long as Northeastern defaulted on its obligation to pay labor and materialmen. Payment of the retained balance became due and available only upon performance by the sureties of Northeastern's obligations. * * *. 22 ****** 23 * * * 24”
6 later decisions quote this exact passage“Rights of subrogation, although growing out of a contractual setting and ofttimes articulated by the contract, do not depend for their existence on a grant in the contract, but are created by law to avoid injustice. Therefore, subrogation rights are not 'security interests' within the meaning of Article 9.”
3 later decisions quote this exact passage“[s]ince the sureties stand in the place of those whose claims they have paid, the funds must be paid to the sureties just as the funds would have gone in the absence of a bond--to the labor and materialmen rather than to the general creditors.”
3 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.