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← 72 U.S. 290 - Christmas v. Russell

Christmas v. Russell’s Empirical Analysis

72 U.S. 290 · 1866

Citation profile

252
cited by 252 later decisions
73
cited 73 times by the Supreme Court
33
states following
July 2013
most recently cited

20 federal appellate · 8 district · 97 state decisions

How this case has been cited

Cited by 252 later decisions (73 by the Supreme Court) — most recently July 2013 · most notably Hilton v. Guyot (1895), Williams v. State of North Carolina (1945)

20 federal appellate · 8 district · 97 state decisions — followed in 33 states

4601866187018801890190019101920193019401950196019701980199020002010decided

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 Mills v. Duryee · President of the Bank of the United States v. Merchants Bank of Baltimore · Anderson v. Anderson

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 252 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““Full faitli and credit shall be given in each state to the public acts, records, and judicial proceedings of every other state.””
    2 later decisions quote this exact passage
  2. ““But the provision under consideration is not a statute of limitations as known to the law or thé decisions of the courts upon that subject. ‘Limitation,’ as used in such statutes, means a bar to the alleged right of the plaintiff to recover in the action created by or arising out of the lapse of a certain time after the cause of action accrued, as appointed by law. Looking at the terms of this provision, it is quite obvious that it contains no element which can give it any such character. Plain effect of the provision is to deny the right of the judgment creditor to sue at all, under any circumstances, and wholly irrespective of any lapse of time whatever, whether longer or shorter. No day is given to such a creditor, but the prohibition is absolute that no action shall be maintained on any judgment or decree falling within the conditions set forth in the provision. These conditions are addressed, not to the judgment, but to the cause of action which was the foundation of the judgment. Substantial import of the provision is that judgment recovered in other states against the citizens of Mississippi shall not be enforced in the tribunals of that state, if the cause of action which was the foundation of the judgment would have been barred in her tribunals by her statute of limitations. * * * It is clear that the statute which is the foundation of the second plea in. this case is unconstitutional and void as affecting the right of the plaintiff to enforce the judgment mentioned”
    1 later decision quote this exact passage · from the majority
  3. “Common law rules placed foreign judgments upon a different footing, and those rules remain, as a general remark; unchanged to the present time. Under these rules, a foreign judgment was prima facie evidence of the debt, and it was open to examination, not only to show that the court in which it was rendered had no jurisdiction of the subject-matter, but also to show that the judgment was fraudulently obtained.”
    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.