Frow v. De La Vega’s Empirical Analysis
82 U.S. 552 · 1872
Citation profile
79 federal appellate · 20 district · 74 state decisions
How this case has been cited
Cited by 298 later decisions (3 by the Supreme Court) — most recently November 2024 · most notably Hohorst v. Packet Co (1893), Carter v. District of Columbia (1986)
79 federal appellate · 20 district · 74 state decisions — followed in 24 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 Pelham v. Way
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 298 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It would be unreasonable to hold, that because one defendant had made default, the plaintiff should have a decree even against him, where the court is satisfied from the proofs offered by the other, that in fact the plaintiff is not entitled to a decree.”
44 later decisions quote this exact passage · from the majority““If one of several defendants to a bill making a joint charge of conspiracy and fraud, make default, his default and a formal decree pro confesso may be entered, but no final decree on the merits until the case is disposed of with regard to the other defendants. The defaulting defendant is simply out of court and can take no farther part in the cause.” (Syl. It 2.)”
1 later decision quote this exact passagee.g. Davis v. Deal“decided the merits of the cause adversely to the complainant and dismissed the bill.”
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.