Case Citator › Trustees of the Philadelphia Baptist Association v. Hart's Executors

Trustees of the Philadelphia Baptist Association v. Hart's Executors

Is it still good law? What later courts have actually done to this case.

Abrogated
Court
Supreme Court of the United States
Citation
17 U.S. 1
Decided
Confirmed treatments
1
Flagged citations read
29 of 29
Citing cases (total)
29
Treatment dates
1844
Abrogated
A reviewed court treats this case as abrogated by later authority. Trustees of the Philadelphia Baptist Association v. Hart's Executors was displaced on its broad premise that equity lacked power, apart from the Statute of Charitable Uses, to enforce an indefinite charitable trust. All 29 flagged citations have been read.
More on how this was screened

The Supreme Court rejected that premise in Vidal v. Girard's Executors and later called it erroneous in Russell v. Allen. Russell explained that the Virginia specific result in Hart continued to be followed under Virginia law. State courts applied their own charitable trust rules.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

29 later cases cite Trustees of the Philadelphia Baptist Association v. Hart's Executors; 29 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

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Treatments

Abrogated

  • The Supreme Court rejected Hart's premise that the English common law supplied no equitable power to enforce indefinite charitable trusts without the Statute of Charitable Uses.

    Vidal v. Girard's Executors · Supreme Court of the United States · filed

    In some of these cases the charities, were not only of an uncertain and indefinite nature,, but, as far as we can gather from the imperfect statement in the printed records, they were also cases where there were either no trustees appointed, or the trustees were not competent to take. These records, therefore, do in a remarkable manner, confirm the opinions of Sir Joseph Jekyll, Lord Northington, Lord Chief Justice Wilmot, Lord Redesdale, and Lord Chancellor Sugden.' Whatever doubts, therefore, might properly be entertained upon the subject when the case of the Trustees of the Philadelphia Baptist Association v. Hart’s Executors, 4 Wheat. 1, was before this court, (1819,) those doubts are entirely removed by the late and more satisfactory sources of information to which we have alluded.
    Read the full opinion on CourtListener →

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