Andrews v. National Foundry & Pipe Works, Ltd.’s Empirical Analysis
76 F. 166 · 1896
Citation profile
9 federal appellate · 1 district ·
How this case has been cited
Cited by 11 later decisions — most recently May 1938
9 federal appellate · 1 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 Burgess v. Seligman · Hawkins v. Glenn · Sanger v. Upton · Bauserman v. Blunt · Handley v. Stutz
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Holding’ the stock by direct issue as collateral security for the debt of the company to them, they could not be liable to the company to pay for the stock as if they had subscribed for it; and, not being liable to the company, they are not liable to the creditors of the company, unless they allowed themselves to be represented as shareholders to creditors who, in giving credit, acted, or should be presumed to have acted, on. the faith of that liability. ‘The liability of a shareholder to pay for stock,’ says the court of appeals of New York in Christensen v. Eno, 106 N. Y. 97 , 102, 12 N. E. 648 , 650, ‘does not arise out of his relation, but depends upon his contract, express or implied, or upon some statute; and, in the absence of either of these grounds of liability, we do not perceive how a person to whom shares have been issued as a gratuity, by accepting them, committed any wrong upon creditors, or made himself liable to pay the nominal face of the shares, as upon a subscription or contract.’ In the same case it is said that: ‘Assuming that the transaction, as to the company, was ultra vires, or that it could not give away its shares, the transaction, in that view, was simply, a nullity, and Eno got nothing as against any one entitled to question the transaction; but it did not convert him into a debtor of the company for the forty per cent. He entered into no contract to pay it.’ This view is more certainly true under the Wisconsin statute, which not only forbids, bu”
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.