McCutcheon v. Merz Capsule Co.’s Empirical Analysis
71 F. 787 · 1896
Citation profile
6 federal appellate · 2 district · 2 state decisions
How this case has been cited
Cited by 13 later decisions (1 by the Supreme Court) — most recently December 1945
6 federal appellate · 2 district · 2 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 Central Transportation Co. v. Pullman's Palace Car Co. · Thomas v. Railroad Co. · St. Louis, Vandalia & Terre Haute Railroad v. Terre Haute & Indianapolis Railroad · Thomas v. City of Richmond · Spring Company v. Knowlton
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““By the agreement of November 29, 1893, which we are asked to sanction and specifically enforce, the Merz Capsule Company contracted not only to sell its entire manufacturing plant, including patents, processes, and good will, to the new corporation, when organized, but that it would never again engage in the same business. If its purpose bad been in good faith to wind up the affairs, and distribute the price to be paid among its stockholders, or to convert the same into money for purposes of distribution, the transaction might be supported, under the authorities heretofore cited, although payment was to be received in stock and bonds of the new company. The implied power to wind up its business and to make a sale of its property would probably authorize a sale for stock in another corporation.””
1 later decision quote this exact passage · from the majority““To hold that the complainant is estopped to rely upon the illegality of the agreement and conveyance to which it was a party would be to effectuate an unexecuted, unlawful object, and aid in the defeat of a legal prohibition. The door of this court should not be closed against one seeking to extricate himself from an unlawful connection, provided relief is sought without delay, and before the contract is executed or other persons have irrevocably acted in reliance upon its supposed legality.””
1 later decision quote this exact passage · from the majority““When tlie immediate and direct effect of an estoppel in equity against relief to a particular plaintiff might he to effectuate an unlawful action, or to defeat a legal prohibition, or to protect a fraud, such an estoppel may well be regarded as against public iiolicy.””
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.