Hackett v. Steele’s Empirical Analysis
1956
Citation profile
7 state decisions
How this case has been cited
Cited by 7 later decisions — most recently March 2019
7 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 Rombauer v. Compton Heights Christian Church · Peck v. Conway · 11 Smith & H. 239 - Ridley v. Haiman · Armstrong v. Leverone · Booker v. Old Dominion Land Co.
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.
““But despite the tendency of some American Courts to adopt a doctrine of comparative benefits, and while a radical change in conditions and in the neighborhood surrounding restricted property will deter practically all American Courts from granting injunctive relief, an analysis of the cases as a whole discloses that equity will enforce restrictive covenants imposed for the benefit of the complainant’s property, if they remain of substantial value, notwithstanding the resulting hardship to the servient estate, where the complainant comes into Court with clean hands and is guiltless of lach-es, waiver or estoppel.””
1 later decision quote this exact passage · from the majoritye.g. Caudill v. Hamlet““Then on page 1171, under subhead ‘d’ changes, where outside restricted tract, section 22, of the annotation are cited several cases where it was held that the changes shown by the evidence occurring outside the restricted area were not sufficient to justify affirmative relief by way of cancellation of the restrictions. While we realize that these cases were not disposed of on demurrer but upon answer and proof, nevertheless, they state the true principle upon which relief is to be granted or denied.””
1 later decision quote this exact passage · from the majoritye.g. Caudill v. Hamlet“It is only when there has been a radical change in the conditions existing when the restrictive covenants were created which completely defeats the objects and purposes of the covenants so that they are no longer effective, and their enforcement would not afford the protection which was in the contemplation of the parties, that equity will hold the restrictions no longer enforceable.”
1 later decision quote this exact passage · from the majoritye.g. Jones v. Englund
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.