Needham v. Hamilton’s Empirical Analysis
1983
Citation profile
4 federal appellate · 7 district · 34 state decisions
How this case has been cited
Cited by 46 later decisions — most recently August 2024 · most notably Krawczyk v. Stingle (1988), Simpson v. Calivas (1994)
4 federal appellate · 7 district · 34 state decisions — followed in 19 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 International Ass'n of Machinists v. Duckworth · Ultramares Corp. v. Touche · 56 Cal. 2d 583 - Lucas v. Hamm · Glanzer v. . Shepard · Savings Bank v. Ward
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a case in which the ability of a nonclient to impose liability would in any way affect the control over the contractual agreement held by the attorney and his client, as the interests of the testatrix and the intended beneficiary with regard to the proper drafting and execution of the will are the same.”
4 later decisions quote this exact passage“Needham was the nephew of Elizabeth McC. Jones. In the summer of 1974, Mrs. Jones directed the appellees [Hamilton] to prepare a new last will and testament for her. Between August and December of 1974 several drafts of the will were prepared by the appellees, each of which named Needham in the thirteenth paragraph as the sole residuary beneficiary. An identical provision was contained in Mrs. Jones’ earlier will which had also been prepared by appellees. Around December 5, 1974, the appellees delivered to Mrs. Jones a draft will designating Needham as the sole residuary beneficiary. Sometime on or after December 5, 1974, Mrs. Jones requested that appel-lees make further changes in the draft will to include certain specific bequests for her grandnieces and grandnephews. In order to accomplish this, appellees inserted a new thirteenth paragraph. Due to some error, this new draft failed to include any residuary clause. Mrs. Jones executed this erroneous will on January 24, 1975, and died on January 26, 1980. The omission was not discovered until January 28,1980, at which time appellees admitted that Needham was to have been named as the sole residuary beneficiary.”
1 later decision quote this exact passagee.g. Hamilton v. Needham
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.