virtual representation doctrine (Missouri) · Go Syfert
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virtual representation doctrine in Missouri

15 Missouri opinions name it 2 courts 1950–2002 0 in the last five years

The cases below were cited by Missouri courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (6)

CaseFollowedCited
Drainage District No. 1 Reformed v. Matthewsgreen
mo · 1950 · cited in 4 Missouri opinions naming this issue, 1957–1981
2 sentences

1974These safeguards are objectively expressed in Drainage District No. 1 Reformed v. Matthews, 234 S.W.2d 567, 574 (Mo.1950): “The doctrine of virtual representation, well recognized in equity, is based upon considerations of necessity and paramount convenience and may be invoked to prevent a failure of justice.

1974These safeguards are objectively expressed in Drainage District No. 1 *121 Reformed v. Matthews, 234 S.W.2d 567, 574 (Mo. 1950): "The doctrine of virtual representation, well recognized in equity, is based upon considerations of necessity and paramount convenience and may be invoked to prevent a failure of justice.

34
Brown v. Bibbgreen
· 1947 · cited in 6 Missouri opinions naming this issue, 1950–1981
2 sentences

1981Insurer seeks solace under the doctrine of virtual representation, citing Brown v. Bibb, 356 Mo. 148 , 201 S.W.2d 370 (banc 1947) and Drainage Dist.

1981Insurer seeks solace under the doctrine of virtual representation, citing Brown v. Bibb, 356 Mo. 148 , 201 S.W.2d 370 (banc 1947) and Drainage Dist.

26
Helton v. Hakegreen
moctapp · 1978 · cited in 2 Missouri opinions naming this issue, 1984–1987
2 sentences

1987First, individual firefighters could be subject to unlimited liability under the doctrine of virtual representation, Helton v. Hake, 564 S.W.2d 313, 322 (Mo.App.1978), and although firefighters who do not assent to strike will not be held responsible, State v. Kansas City Firefighters Local supra, 672 S.W.2d at 125 , this potential for liability may prevent competent persons from pursuing careers as firefighters.

1984Helton v. Hake, 564 S.W.2d 313, 322 [12] (Mo.App.1978); Sommer v. City of St.

22
In Re Estate of Remmelegreen
moctapp · 1993 · cited in 1 Missouri opinions naming this issue, 2002–2002
1 sentence

2002See In re Estate of Remmele, 853 S.W.2d 476, 482 (Mo.App.1993) (holding interests of non-joined parties adequately protected based on the doctrine of virtual representation).

11
Campbell v. Webbgreen
mo · 1953 · cited in 1 Missouri opinions naming this issue, 1960–1960
2 sentences

1960See Campbell v. Webb, 363 Mo. 1192 , 258 S.W.2d 595 , loc. cit. page 601, wherein the only difference between the equitable doctrine of virtual representation and their statutory class action is said to be the requirements of Supreme Court Rule 3.07.

1960See Campbell v. Webb, 363 Mo. 1192 , 258 S.W.2d 595 , loc. cit. page 601, wherein the only difference between the equitable doctrine of virtual representation and their statutory class action is said to be the requirements of Supreme Court Rule 3.07.

11
Robinson v. Nickgreen
moctapp · 1940 · cited in 1 Missouri opinions naming this issue, 1950–1950
2 sentences

1950And there are several Missouri decisions rendered both before and after the enactment of the fore; going Code provision in 1943, holding such rights may be determined [9] in equity even in the absence of a statute so permitting, under the doctrine of virtual representation. 3 In particular it was held in Robinson v. Nick et al., 235 Mo. App. 461, 479-80 (2, 3), 136 SW. (2d) 374, 385 (2-5), decided in 1940, that the doctrine of virtual representation applied to labor unions.

1950And there are several Missouri decisions rendered both before and after the enactment of the fore; going Code provision in 1943, holding such rights may be determined [9] in equity even in the absence of a statute so permitting, under the doctrine of virtual representation. 3 In particular it was held in Robinson v. Nick et al., 235 Mo. App. 461, 479-80 (2, 3), 136 SW. (2d) 374, 385 (2-5), decided in 1940, that the doctrine of virtual representation applied to labor unions.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Missouri. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
White v. City of Columbia green
mo · 1970
1 sentence

1988In holding the subsequent attack was not barred, the court said the following: In view of that situation we do not think it would be just and equitable to hold that the virtual representation doctrine is fully applicable and that these plaintiffs are barred from litigating the issue of reasonableness of the annexation because of the White [v. City of Columbia, 461 S.W.2d 806 (Mo. banc 1970) ] judgment.

11988–1988
State Ex Inf. Ashcroft v. Kansas City Firefighters Local No. 42 green
moctapp · 1984
1 sentence

1987First, individual firefighters could be subject to unlimited liability under the doctrine of virtual representation, Helton v. Hake, 564 S.W.2d 313, 322 (Mo.App.1978), and although firefighters who do not assent to strike will not be held responsible, State v. Kansas City Firefighters Local supra, 672 S.W.2d at 125 , this potential for liability may prevent competent persons from pursuing careers as firefighters.

11987–1987
Seibert v. City of Columbia green
mo · 1970
2 sentences

1972Seibert v. City of Columbia, Mo., 461 S.W.2d 808 .

1972Seibert v. City of Columbia, Mo., 461 S.W.2d 808 .

11972–1972
Clark v. Grand Lodge of the Brotherhood of Railroad Trainmen green
· 1931
2 sentences

1960The present case is not upon an insurance contract, or other contract, entered into by an unincorporated association in circumstances considered sufficient to bring it within certain statutory provisions relating to such contracts, as was the situation in Clark v. Grand Lodge, etc., 328 Mo. 1084 , 43 S.W.2d 404 [11-14], 88 A.L.R. 150 .

1960The present case is not upon an insurance contract, or other contract, entered into by an unincorporated association in circumstances considered sufficient to bring it within certain statutory provisions relating to such contracts, as was the situation in Clark v. Grand Lodge, etc., 328 Mo. 1084 , 43 S.W.2d 404 [11-14], 88 A.L.R. 150 .

11960–1960
Powell v. City of Joplin green
mo · 1934
2 sentences

1957See Drainage District No. 1, Reformed of Stoddard County, v. Matthews, 361 Mo. 286 , 234 S.W.2d 567, 572 ; Powell v. City of Joplin, 335 Mo. 562 , 73 S.W.2d 408 .

1957See Drainage District No. 1, Reformed of Stoddard County, v. Matthews, 361 Mo. 286 , 234 S.W.2d 567, 572 ; Powell v. City of Joplin, 335 Mo. 562 , 73 S.W.2d 408 .

11957–1957

Where else courts name it

TX 109 (1920–2025) CA 23 (1952–2024) MO 15 (1950–2002) KY 12 (1923–2024) NJ 5 (1953–2003) TN 5 (1921–1997) WA 5 (2005–2024) IL 3 (2014–2015) IN 3 (1968–1971) NY 3 (1961–1992) NM 3 (1929–2010) MI 2 (2017–2017) VA 2 (1927–1997) LA 2 (1954–2009) DE 2 (1977–1997) NC 2 (1994–2010) OH 2 (1922–1929) AR 2 (1956–1975)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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