United States v. Rowe’s Empirical Analysis
56 F.2d 747 · 1932
Citation profile
57 federal appellate · 4 district · 12 state decisions
How this case has been cited
Cited by 95 later decisions (5 by the Supreme Court) — most recently May 2025 · most notably Neder v. United States (1999), Adams v. United States Ex Rel. McCann (1943)
57 federal appellate · 4 district · 12 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 Durland v. United States · Van Riper v. United States · United States v. Comyns · Vulcan Metals Co. v. Simmons Mfg. Co. · Wilson v. United States
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 95 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A man is none the less cheated out of his property, when he is induced to part with it by fraud, because he gets a quid pro quo of equal value. It may be impossible to measure his loss by the gross scales available to a court, but he has suffered a wrong; he has lost his chance to bargain with the facts before him. That is the evil against which the statute is directed.”
23 later decisions quote this exact passage · from the majority““True, the law still recognizes that in bargaining parties will puff their wares in terms which neither side means seriously, and which either so takes at his peril * * *; but it is no longer law that declarations of value can never be a fraud. Like other words, they get their color from their setting, and mean one thing when exchanged between traders, and another when uttered by a broker to his customer. Values are facts as much as anything else * * (Emphasis added.)”
2 later decisions 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.