Ryan v. Hebert’s Empirical Analysis
1924
Citation profile
1 federal appellate · 6 state decisions
How this case has been cited
Cited by 7 later decisions — most recently July 1943
1 federal appellate · 6 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 Dunham v. Blood
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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Section 20 (G. S. § 4378) was copied from the German Exchange Act, and some of its provisions are a departure from the prevailing rule in this country. This section has been subjected to severe criticism, but it has outlived it, due to the fact that the business world approves of it because it increases the negotiability of commercial paper and simplifies the proof in the recovery. Article by Charles L. MeKeehan, published in Bran-nan’s Negotiable Instrument Law. * * * “This- section covers at least five classes of cases: “(1) Where one adds to his signature to a negotiable instrument words indicating that he signs for or on behalf of a principal, or in a representative capacity, he is not liable on the instrument if he was duly authorized. “(2) By necessary implication from this statute, as Mr. Crawford and Prof. Brannan have pointed out in their works on the Negotiable Instruments Law, it follows: Where one adds to his signature to a negotiable instrument words indicating that he signs for or on behalf of a principal or in a representative capacity, he is liable on the instrument if he was not duly authorized. “(3) Where one adds to his signature to a negotiable instrument words describing him as an agent, or as filling a representative character without disclosing his principal, he will be personally liable. “(4) By necessary implication it follows: Where one adds to Ms signature to a negotiable instrument words describing him as an agent or as filling a representative ch”
1 later decision quote this exact passagee.g. Pain v. Holtcamp““Agents, When Not Liable. — Where the instrument contains or a person adds to his signature words indicating that he signs for or on behalf of a principal or in a representative capacity, he is not liable on the instrument if he was duly authorized; but the mere addition of words describing him as agent, or as filling a representative character, without disclosing his principal, does not exempt him from personal liability.””
1 later decision quote this exact passagee.g. Pain v. Holtcamp
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.