54 Ill. App. 3d 141 - Maynard v. Parker’s Empirical Analysis
1977
Citation profile
4 federal appellate · 49 state decisions
How this case has been cited
Cited by 69 later decisions — most recently July 2025 · most notably 193 Ill. 2d 560 - Morris B. Chapman & Associates, Ltd. v. Kitzman (2000), 77 Ill. App. 3d 343 - Woodfield Ford, Inc. v. Akins Ford Corp. (1979)
4 federal appellate · 49 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 66 Ill. 2d 119 - Baier v. State Farm Insurance Co. · 23 Ill. App. 3d 607 - MID-WEST NATL. BK. OF LAKE FOREST v. Metcoff · 59 Ill. 2d 61 - Flynn v. Kucharski · 87 Wash. 2d 796 - Hsu Ying Li v. Tang · SISTERS OF CHARITY OF PROV. OF MONT. v. Nichols
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 69 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We cannot justify extending the common fund doctrine to require a mortgagee or a furniture store or any other creditor (World Express) of a plaintiff (MBM) to contribute to the fees of the plaintiff's attorney if the funds recovered by the litigation are used to satisfy the plaintiff's obligations.”
5 later decisions quote this exact passage · from the majority“This analogy is inapt and the principle inapplicable here. The obligation of the subrogated insurer to share in the costs of recovery from a third party wrongdoer arises because the insurer occupies the position of the insured with coextensive rights and liabilities and no creditor-debtor relationship between them. . . . [T]he hospital's claim and lien is based upon a debt owed the hospital by its patient in whose shoes it does not stand for any purpose, the debt being owed to it by its patient irrespective of the patient's rights against a third party wrongdoer.”
2 later decisions quote this exact passage · from the majority“the right of an attorney to recover for professional services must rest on the terms of a contract of employment, either express or implied, with the person sought to be charged, and cannot be based on a benefit derived by a third party from the services rendered by the attorney.”
1 later decision quote this exact passage · from the majority
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.