Delaware v. New York’s Empirical Analysis
1993
Citation profile
19 federal appellate · 23 district · 37 state decisions
How this case has been cited
Cited by 131 later decisions (3 by the Supreme Court) — most recently May 2025 · most notably American Express Travel Related Services, Inc. v. Sidamon-Eristoff (2012), 24 F. Supp. 2d 1013 - Cairns v. Franklin Mint Co. (1998)
19 federal appellate · 23 district · 37 state decisions — followed in 10 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 Board of Regents of State Colleges v. Roth · Paul v. Davis · Bishop v. Wood · United States v. Detroit Timber & Lumber Co. · Walker v. Armco Steel Corp.
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 131 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Funds held by a debtor become subject to escheat because the debtor has no interest in the funds — precisely the opposite of having “a claim to the funds as an asset.” We have recognized as much in cases upholding a State’s power to escheat neglected bank deposits. Charters, bylaws, and contracts of deposit do not give a bank the right to retain abandoned deposits, and a law requiring the delivery of such deposits to the State affects no property interest belonging to the bank. [Sec. Sav. Bank, 263 U.S. at 285-86 , 44 S.Ct. 108 ]; Provident Institution for Sav. v. Malone, 221 U.S. 660 , 665-66, 31 S.Ct. 661 , 55 L.Ed. 899 (1911). Thus, “deposits are debtor obligations of the bank,” and a State may “protect the interests of depositors” as creditors by assuming custody over accounts “inactive so long as to be presumptively abandoned.” [Anderson Nat. Bank, 321 U.S. at 241 , 64 S.Ct. 599 ] (emphasis added). Such “disposition of abandoned property is a function of the state,” a sovereign “exercise of a regulatory power” over property and the private legal obligations inherent in property. [Standard Oil Co. v. New Jersey, 341 U.S. 428 , 436, 71 S.Ct. 822 , 95 L.Ed. 1078 (1951) ].”
8 later decisions quote this exact passage · from the majority“To say that “a debt follows the debtor” is simply to say that intangible property has no actual situs, and a debt may be sued on wherever there is jurisdiction over the debtor. State Farm is “found,” in the sense of doing business, in all 50 States and the District of Columbia. Under appellee’s theory, the “debt” owed to Rush would be “present” in each of those jurisdictions simultaneously. It is apparent that such a “contact” can have no jurisdictional significance.”
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.