Case Citator › Noonan v. Lee

Noonan v. Lee

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

Superseded by statute
Court
Supreme Court of the United States
Citation
67 U.S. 499
Decided
Confirmed treatments
1
Flagged citations read
3 of 3
Citing cases (total)
3
Treatment dates
1921
Superseded by statute
A reviewed court treats this case as superseded by later legislation. Superseded by a later court rule. Supreme Court equity Rule 92 displaced Noonan's bar on a personal deficiency decree in a federal mortgage foreclosure, as Continental-Equitable Title & Trust Co. v. National Properties Co. held.
More on how this was screened

All three flagged citations have been read. The Constitution Annotated lists Noonan as overruled by Hornbuckle v. Toombs, but Hornbuckle said Noonan's objection remained available in federal circuit and district courts; it rejected Orchard v. Hughes's extension of that rule to territorial courts.

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.

3 later cases cite Noonan v. Lee; 3 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.

Relying on Noonan v. Lee?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Superseded by statute

  • The district court held that the later Supreme Court equity rule displaced Noonan's former bar on foreclosure deficiency decrees.

    Continental-Equitable Title & Trust Co. v. National Properties Co. · U.S. District Court for the District of Delaware · filed

    Formerly it was not competent for the federal courts, in a suit for the foreclosure of a mortgage, to render a decree for any balance that might be found due over and above the proceeds of the sale. Noonan v. Lee, 67 U. S. (2 Black) 499, 17 L. Ed. 278. ... To abrogate the exception rule 92 was promulgated by the Supreme Court. 68 U. S. vii. That rule, as now embodied in equity rule 10, provides:
    Read the full opinion on CourtListener →

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