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← 74 U.S. 425 - Payne v. Hook

Payne v. Hook’s Empirical Analysis

74 U.S. 425 · 1868

Citation profile

577
cited by 577 later decisions
62
cited 62 times by the Supreme Court
11
states following
June 2025
most recently cited

213 federal appellate · 69 district · 18 state decisions

How this case has been cited

Cited by 577 later decisions (62 by the Supreme Court) — most recently June 2025 · most notably Grupo Mexicano Desarrollos v. Alliance Bond Fund Inc, Sprage v. Ticonic Nat Bank (1939)

213 federal appellate · 69 district · 18 state decisions — followed in 11 states

98018681870188018901900191019201930194019501960197019801990200020102020decided

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.

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

  1. ““We have repeatedly held ‘that the jurisdiction of the courts of the United States over controversies between citizens of different states cannot be impaired by the laws of the states, which prescribe thé modes of redress in their courts, or which regulate the distribution of their judicial power.’ If legal remedies are sometimes modified to suit the changes in the laws of the states and the practice of their courts, it is not so with equitable. The equity jurisdiction conferred on the federal courts is the same that the high court of chancery in England possesses, is subject to neither limitation nor restraint by state legislation, and is uniform throughout the- different states of the Union.””
    16 later decisions quote this exact passage · from the majority
  2. ““But it is said the proper parties for a decree are not before the court, as the bill shows there are other distributees besides the complainant. It is undoubtedly true ‘that all persons materially .interested in the subject-matter of the suit should be made parties to it; but this rule, like all general rules, being founded in convenience, will yield whenever it is necessary that it should yield in order to accomplish the ends of justice. It will yield, if the court is able to proceed to a decree, and do justice to the parties before it, without injury to absent persons, equally interested in the litigation, but who cannot conveniently be made parties to the suit. The necessity for the relaxation of the rule is more especially apparent in the courts of the United States, where oftentimes, the enforcement of the rule would oust them of their jurisdiction, and deprive parties entitled to the interposition of a court of equity of any remedy whatever. * * * It can never be indispensable to make defendants of those against whom nothing is alleged and from whom no relief is asked. A court of equity adapts its decrees to the necessities of each ease, and should the present suit terminate in a decree against the defendants, it is easy to do substantial justice to all the parties in interest and prevent a multiplicity of suits by allowing the other distributees, either through a reference to a master, or by some other proper proceeding, to come in and share in the benefit of the liti”
    7 later decisions quote this exact passage · from the majority
  3. ““The absence of a complete and adequate remedy at law is the only test of equity jurisdiction, and the application of this principle to a particular case must depend on the character of the case as disclosed in the pleadings.””
    3 later decisions 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.