Steele v. Smith’s Empirical Analysis
1910
Citation profile
3 federal appellate · 1 district · 5 state decisions
How this case has been cited
Cited by 9 later decisions — most recently April 1952
3 federal appellate · 1 district · 5 state decisions
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 Ellen v. Ellen · Young v. McNeill · Cribb v. Rogers · Howard v. Henderson · Ayer v. Ritter
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The argument to this point is keen and forceful, and there is some high authority for the view. But we think it is clear that the trust in this case is such an executory trust as will prevent the application of the rule in Shelley’s Case. In order to convey the fee to the appointee of the life tenant, it was essential to the performance of his duty that the trustee retain the title in fee until it was ascertained that there was default of such appointment at the termination of the life estate. The trust was not a perfect trust, as it involves for its full execution the exercise or failure to exercise discretionary power of appointment by the life tenant. * * * Hence the case clearly falls within the definition of an executory trust in Perry on Trusts, relied upon by appellant.””
1 later decision quote this exact passage · from the majority““in trust as to the one-half of said piece, parcel or tract of land to stand soised and possessed of the same for the use and benefit of my grandson, the above mentioned John G. Steele for and during the term of his natural life; and at Ms death to transfer and convey the same to such person or persons as he the said John G. Steele may by his will direct, or in default of such will and direction to the heirs of him the said John G. Steele in fee."”
1 later decision quote this exact passage · from the majority““Plaintiffs claim that John G. Steele had. only a life estate, and having hied without executing the power * * * by will, they are entitled to partition * * * as heirs of John G. Steele, and remaindermen under the deed of John Steele, Sr. The court sustained this contention. The defendants appellants conteud that under the rule in Shelley’s Case John G. Steele had a fee-simple estate, * * * which they acquired.””
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.