Pennsylvania College Cases’s Empirical Analysis
80 U.S. 190 · 1871
Citation profile
1 district · 24 state decisions
How this case has been cited
Cited by 58 later decisions (15 by the Supreme Court) — most recently April 2018 · most notably Late Corporation of the Church of Jesus Christ of Latter-Day Saints v. United States (1890), Gibbs v. Consolidated Gas Co. of Baltimore (1889)
1 district · 24 state decisions — followed in 14 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 Wheeler v. Harris · Sherman v. Smith
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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Cases often arise where the Legislature, in granting an act of incorporation for a private purpose, either make the duration of the charter conditional, or reserve to the state the power to alter, modify, or repeal the same at pleasure. When such a provision is incorporated in the charter it is clear that it qualifies the grant, and that the subsequent exercise of that reserved power cannot be regarded as an act within the prohibition of the Constitution. Such a power also — that is, the power to alter, modify, or repeal an act of incorporation — is frequently reserved to the state by a general law applicable to all acts of incorporation, or to certain classes of the same, as the case may be, in which case it is equally clear that the power may be exercised whenever it appears that the act of incorporation is one which falls within the reservation, and that the charter was granted subsequent to the passage of the general law even though the charter contained no such condition, nor any allusion to such a reservation. Reservations in such a charter, it is admitted, may be made, and it is also conceded that, where they exist the exercise of the power reserved by a subsquent Legislature does not impair the obligation of the contract created by the original act of incorporation. Subsequent legislation, altering or modifying the provisions of such a charter, where there is no such reservation, is certainly unauthorized if it is prejudicial to the rights of the corporators and was ”
1 later decision quote this exact passage · from the majority““The Legislature shall have power to alter, revoke, or annul any. charter of incorporation hereafter conferred by or under any special or general law, whenever, in their opinion, it may be injurious to the citizens of the commonwealth; in such manner, howrever, that no injustice shall be done to the corporators.””
1 later decision quote this exact passage
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.