Gartner v. Snyder’s Empirical Analysis
607 F.2d 582 · 1979
Citation profile
17 federal appellate · 4 district ·
How this case has been cited
Cited by 82 later decisions — most recently October 2018 · most notably New York v. Shore Realty Corp. (1985), Wm. Passalacqua Builders, Inc. v. Resnick Developers South, Inc. (1991)
17 federal appellate · 4 district ·
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 Walkovszky v. Carlton · Port Chester Electrical Construction Corp. v. Atlas · Bartle v. Home Owners Cooperative, Inc. · Luckenbach S. S. Co. v. W. R. Grace & Co.
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Because New York courts disregard corporate form reluctantly, they do so only when the form has been used to achieve fraud, or when the corporation has been so dominated by an individual or another corporation (usually a parent corporation), and its separate identity so disregarded, that it primarily transacted the dominator’s business rather than its own and can be called the other’s alter ego.”
11 later decisions quote this exact passage · from the majority“allow[ ] individuals to incorporate for the very purpose of avoiding personal liability,”
2 later decisions quote this exact passage · from the majority“The law permits the incorporation of a business for the very purpose of enabling its proprietors to escape personal liability ... but, manifestly, the privilege is not without its limits. Broadly speaking, the courts will disregard the corporate form, or, to use accepted terminology, pierce the corporate veil, whenever necessary to prevent fraud or to achieve equity.... In determining whether liability should be extended to reach assets beyond those belonging to the corporation, we are guided, as Judge Cardozo noted, by general rules of agency.... In other words, whenever anyone uses control of the corporation to further his own rather than the corporation’s business, he will be liable for the corporation’s acts upon the principle of respon-deat superior applicable even where the agent is a natural person.”
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.