Hanger v. Abbott’s Empirical Analysis
73 U.S. 532 · 1867
Citation profile
41 federal appellate · 12 district · 41 state decisions
How this case has been cited
Cited by 186 later decisions (24 by the Supreme Court) — most recently June 2026 · most notably Banco Nacional De Cuba v. Sabbatino (1964), Soriano v. United States (1957)
41 federal appellate · 12 district · 41 state decisions — followed in 22 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 Armitz Drown v. The United States · The Rapid, Perry, Master · William Maley v. Jared Shattuck
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 186 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Total inability on the part of an enemy creditor to sustain any contract in the tribunals of the other belligerent exists during war, but the restoration of peace removes the disability, and opens the doors of the courts. Absolute suspension of the right, and prohibition to exercise it, exist during war by the law of nations, and if so, then it is clear that peace cannot bring with it the remedy if the war is of much duration, unless it also be held that the operation of the statute of limitation is also suspended during the period the creditor is prohibited, by the existence of the war and the law of nations, from enforcing his claim. Neither laches nor fraud can be imputed in such a case, and none of the reasons on which the statute is founded can possibly apply, as the disability to sue becomes absolute by the declaration of war, and is a conclusion of law. Ability to sue was the status of the creditor when the contract was made, but the effect of war is to suspend the right, not only without any fault on his part, but under circumstances which make it his duty to abstain from any such attempt. His remedy is suspended by the acts of the two governments and by the law of nations, not applicable at the date of the contract, but which comes into operation in consequence of an event over which he has no control.””
2 later decisions quote this exact passage · from the majority““Unless we return the remedy with the right the pretence of restoring the latter is a mockery, as the power to exe-cise it with effect is gone by lapse of time during which both the right and the remedy were suspended. * * sK ❖ 'Jf- * “ * * * Peace restores the right and the remedy, and as that cannot be if the limitation continues to run during the period the creditor is rendered incapable to sue, it necessarily follows that the operation of the statute is also suspended during the same period.””
1 later decision quote this exact passage · from the majority““War, when duly declared or recognized as such by the war-mahing power, Imports a prohibition to the subjects, or citizens, of all commercial intercourse and correspondence with citizens or persons domiciled in the enemy country. Upon this principle of public law it is the established rule, in all commercial nations, that trading with the enemy, except under a government license, subjects the property to confiscation, or to capture and condemnation.””
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.