Covell v. Heyman’s Empirical Analysis
111 U.S. 176 · 1884
Citation profile
288 federal appellate · 136 district · 105 state decisions
How this case has been cited
Cited by 794 later decisions (56 by the Supreme Court) — most recently October 2023 · most notably Darr v. Burford (1950), Kline v. Burke Construction Co. (1922)
288 federal appellate · 136 district · 105 state decisions — followed in 30 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 Wayman v. Southard · Freeman v. Howe · Krippendorf v. Hyde · James L. v. Carryl
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 794 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[B]ut between state courts and those of the United States, it is something more. It is a principle of right and of law, and therefore of necessity. It leaves nothing to discretion or mere convenience. These courts do not belong to the same system, so far as their jurisdiction is concurrent; and although they co-exist in the same space, they are independent, and have no common superior.”
40 later decisions quote this exact passage · from the majority“[T]he powers of the General Government, and of the State, although both exist and are exercised within the same territorial limits, are yet separate and distinct sover-eignties, acting separately and independently of each other, within their respective spheres. And the sphere of action appropriated to the United States is as far beyond the reach of the judicial process issued by a State judge or a State court, as if the line of division was traced by landmarks and monuments visible to the eye.”
4 later decisions quote this exact passage · from the majoritye.g. Moran v. Sturges · Rodgers v. Pitt“exercis[ing] jurisdiction for the purpose of enforcing the supremacy of the Constitution and laws of the United States”
4 later decisions 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.