Sparks v. Pierce’s Empirical Analysis
115 U.S. 408 · 1885
Citation profile
21 federal appellate · 14 district · 42 state decisions
How this case has been cited
Cited by 112 later decisions (12 by the Supreme Court) — most recently July 2006 · most notably Lee v. Johnson (1885), Northern Pac Ry Co v. McComas (1919)
21 federal appellate · 14 district · 42 state decisions — followed in 13 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 Bohall v. Dilla
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 112 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Mere occupancy of the public lands and improvements thereon give no vested right therein as against the United States, and consequently not against any purchaser from them.””
2 later decisions quote this exact passage · from the majority“When [a person] has once obtained the patent of the United States for his land, he should be only required to answer persons who have some established claim. ") (emphasis added); Sparks v. Pierce, 115 U.S. 408 , 413, 6 S.Ct. 102, 29 L.Ed. 428 (1885) ("To entitle a party to relief against a patent of the government, he must show a better right to the land than the patentee, such as in law should have been respected by the officers of the land department, and being respected would have given him the patent. It is not sufficient to show that the patentee ought not to have received the patent. It must affirmatively appear that the claimant was entitled to it, and that, in consequence of erroneous rulings of those officers on the facts existing, it was denied to him.”
1 later decision quote this exact passage · from the majority“A person who makes improvements upon public land, knowing that he has no title, and that the land is open to exploration and sale for its minerals, and makes no effort to secure the title to it as such land under the laws of Congress, . . . has no claim to compensation for his improvements as an adverse holder in good faith when such sale is made to another and the title is passed to him by a patent of the United States.”
1 later decision 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.