Sampson Lord and George Jenness v. John Goddard’s Empirical Analysis
54 U.S. 198 · 1851
Citation profile
23 federal appellate · 11 state decisions
How this case has been cited
Cited by 46 later decisions (2 by the Supreme Court) — most recently June 2006 · most notably Claflin v. Commonwealth Insurance (1884), Claflin v. Commonwealth Ins Co of Boston Massachusetts Same
23 federal appellate · 11 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 Benton v. Pratt · Allen v. Addington · Young & Otis v. Covell · Williams v. Wood
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.
““The gist of the action is fraud in the defendants and damage to the plaintiff. Fraud means an intention to deceive. If there was not such intention ; if the party honestly stated his opinion, believing at the time that he stated the truth—he is not liable in this form of action, although the representation turned out to be entirely untrue. Since the decision in Haycroft v. Creasy, 2 East, made in 1801, the question has been settled to this effect in England. The Supreme Court of New York held likewise in Young v. Covell, 8 Johns, 23 , 5 Am. Dec. 316 . That court declared it to be well settled that this action could not be sustained without proving actual fraud in the defendant, or an intention to deceive the plaintiff by false representations. The simple fact of making representations which turn out not to be true, unconnected with a fraudulent design, is'not sufficient. This decision was made forty years ago, and stands uncontradicted, so far as we know, in the American courts.””
3 later decisions quote this exact passage · from the majority“[T]he action [of fraud] cannot be maintained without showing affirmatively knowledge of its falsity.”
2 later decisions 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.