Cromwell v. County of Sac’s Empirical Analysis
96 U.S. 51 · 1877
Citation profile
75 federal appellate · 9 district · 87 state decisions
How this case has been cited
Cited by 246 later decisions (23 by the Supreme Court) — most recently August 1991 · most notably Parklane Hosiery Co. v. Shore (1979), Federated Department Stores, Inc. v. Moitie (1981)
75 federal appellate · 9 district · 87 state decisions — followed in 35 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 Cromwell v. County of Sac · United States v. Union Pacific Railroad · Timothy Goodman v. John Simonds · Murray v. Lardner
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 246 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The rule has been too long settled to be questioned now, that whenever negotiable paper [and he was here speaking of dishonored municipal bonds] has passed into the hands of a party, unaffected by previous infirmities, its character as an available security is established, and its holder can transfer it to others with the like immunity. His own title and right would be impaired if any restrictions were placed upon his power of disposition.””
3 later decisions quote this exact passage · from the majority““The nonpayment of an installment of interest when due could not affect the negotiability of the bonds or of the subsequent coupons. Until their maturity,-a purchaser for value, without notice of their invalidity as between antecedent parties, would take them discharged from all infirmities. The nonpayment of the installment of interest represented by the coupons due at the commencement of the month in which the purchase was made by Clark was a slight circumstance, and, taken in connection with the fact that previous coupons had been paid, was entirely insufficient to excite suspicion even of any illegality or irregularity in the issue of the bonds.””
1 later decision quote this exact passage · from the majority““As with other negotiable paper, mere suspicion that there may be a defect of title in its holder, or knowledge of circumstances which would excite suspicion as to his title in the mind of a prudent man, is not sufficient to impair the title of the purchaser. That result will only follow where there has been bad faith on his part.””
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.