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← 57 WASH 359 - Palmquist v. Sagstad

Palmquist v. Sagstad’s Empirical Analysis

1910

Citation profile

55
cited by 55 later decisions
2
states following
August 1997
most recently cited

4 federal appellate · 2 district · 48 state decisions

How this case has been cited

Cited by 55 later decisions — most recently August 1997 · most notably Thomas Christianson v. County of King (1915), 20 Wash. 2d 740 - Tucker v. Brown (1944)

4 federal appellate · 2 district · 48 state decisions

150191019201930194019501960197019801990decided

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 Cunha v. Hughes · Ryan v. Fergusson · Griffin v. Warburton · Bower v. Bower · Van Brocklin 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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Its very object and purpose is to judicially determine who takes the property left by the deceased. The only question here to determine is, was that decree a final determination of the rights of [the distributee] in and to these lots, binding upon all persons making claim thereto as heirs of Elsie Ostlund.”
    2 later decisions quote this exact passage
  2. ““It is settled law in this state that orders and decrees of distribution made by superior courts in probate proceedings upon due notice as provided by statute are final adjudications having the effect of judgments in rem, and are conclusive and binding upon all persons having any interest in the estate and upon all the world as well. [Many cases cited.] “Such decrees cannot be attacked or annulled in any collateral proceeding, except for fraud. [Cases cited.] ***** “Appellant’s next contention is that the property was sold without the actual knowledge of appellant or of any of the heirs. There is no statute in this state which requires that personal notice of sales of real property in probate proceedings be given to persons who are interested in the estate. The administration of an estate is a proceeding in rem, and when real property belonging to the estate is ordered to be sold, the statute requires only that notice of sale be given by posting and publication, whether the sale be by public auction * * *, or at private sale. * * * Likewise, notice by posting and publication, only, is required with respect to the hearing of the final report and petition for distribution. [Authorities cited.]””
    1 later decision quote this exact passage
  3. ““The contention that the court, in rendering the decree, erroneously determined who was entitled to the property as distributee upon distribution of the estate of Elsie Ostlund, goes only to the merits of the question then before the court, and is wholly foreign to the question of the jurisdiction of the court to determine who was entitled to the property then being distributed. ... It is true the decree does not create the title in the distributees, but it is a solemn adjudication of who acquired the title of the deceased, and if rendered upon due process of law is final and conclusive upon that question. Its very object and purpose is to judicially determine who takes the property left by the deceased.””
    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.