Trowbrigde v. Forepaugh
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Citation treatment has not been reviewed for this case. The notes below come from the citation graph and the Minnesota Revisor's amendment records, not from a review of how later courts treated this decision.
(as of 9/30/2026)
Last cited by a Minnesota appellate court in 1892, among the opinions in this site’s citation index.
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Cases that cite this one
9 later published cases cite this decision.
- Livermore v. County of Norfolk (Mass. 1904)
- MacDonald v. St. Louis Transit Co. (Mo. Ct. App. 1904)
- Helms v. Northern Pac. Ry. Co. (U.S. Circuit Court for the District of Minnesota 1903)
- Kelly v. Chicago & A. Ry. Co. (U.S. Circuit Court for the District of Western Missouri 1903)
- City of Kansas v. File (Kan. 1899)
- Carmichael v. City of Texarkana (U.S. Circuit Court for the District of Western Arkansas 1899)
- Hayden v. Pearce (Or. 1898)
- Langevin v. City of St. Paul (Minn. 1892)
- Mooney v. Third Avenue Railroad (City of New York Municipal Court 1886)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
By the Gourt
The liability of the city depends on a state of facts not affecting its co-defendants ; and the converse. Neither is in fact nor in law chargeable with, or liable on account of the matter set up as a cause of action against the other. They did not- jointly conduce to the injury by any acts either of omission or commission.
Under such circumstances we find no case holding that a joint action is maintainable; and' we are of the opinion that it is unauthorized by any statute or legal principle. Our statute, which is merely declaratory of the common law, forbids the joinder of causes of action which do not affect all the parties to the action. Gen. Stat. Chap. 66, Sec. 98. Por such improper joinder of causes of action any defendant may demur. There is nothing in the statute, and we discover no reason requiring all the defendants to- join in such demurrer.
Order affirmed.
Case-law data current through September 30, 2026. Source: CourtListener bulk data.