Patch v. White’s Empirical Analysis
117 U.S. 210 · 1886
Citation profile
13 federal appellate · 138 state decisions
How this case has been cited
Cited by 175 later decisions (9 by the Supreme Court) — most recently March 2016 · most notably Helvering v. New York Trust Co. (1934), Morris v. United States (1899)
13 federal appellate · 138 state decisions — followed in 32 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 John Smith v. Robert Bell · Reed v. Insurance Co. · John Inglis v. The Trustees of the Sailor's Snug Harbour in the City of New York · Alexander Finlay v. William King's Lessee
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 175 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is settled doctrine that as a latent ambiguity is only disclosed by extrinsic evidence, it may be removed by extrinsic evidence. Such an ambiguity may arise upon a will, either when it names a person as the object of a gift, or a thing as the subject of it, and there are two persons or things that answer such name or description; or, secondly, it may arise when the will contains a misdescription of the object or subject; as where there is no such person or thing in existence, or, if in existence, the person is not the one intended, or the thing does not belong to the testator. (Emphasis ours)”
4 later decisions quote this exact passage · from the majority“The devise clearly and without uncertainty designates a lot on Ninth street, between I and K streets, well known on the map of the city of Washington, whose metes, bounds and area are definitely fixed, platted and recorded. The map referred to was approved by President Washington in 1792 and recorded in 1791. Thousands of copies of it have been engraved and printed. All conveyances of real estate in the city made since it was put on the record refer to it; it is one of the muniments of title to all the public and private real estate in the city of Washington, and it is probably better known than any document on record in the District of Columbia. The accuracy of the description of the lot devised is, therefore, matter of common knowledge, of which the court might even take judicial notice.”
1 later decision quote this exact passage · from the dissent““It seems to us that this evidence, taken in connection with the whole tenor of the will, amounts to demonstration as to which lot was in the testator’s mind. It raises a latent ambiguity. The question is one of identification between two lots, to determine which was in the testator’s mind, whether lot 3, square 406, which he owned, and which had improvements erected ‘thereon, and thus corresponded with the implications of the will, and with part of the description of the lot, and rendered the devise effective; or lot 6, square 403, which he did not own, which had no improvements thereon, and which rendered the devise ineffective.””
1 later decision quote this exact passage · from the majoritye.g. Taylor v. Horst
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.