Mullan v. United States’s Empirical Analysis
118 U.S. 271 · 1886
Citation profile
27 federal appellate · 7 district · 4 state decisions
How this case has been cited
Cited by 85 later decisions (31 by the Supreme Court) — most recently August 1979 · most notably United States v. American Bell Telephone Co. (1897), Wisconsin Central Railroad v. United States (1896)
27 federal appellate · 7 district · 4 state decisions
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 Steel v. St Louis Smelting Refining · United States v. Schurz · Moore v. Robbins · United States v. Stone · Moffat v. United States
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 85 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“This is clearly a legislative declaration that `known' coal lands were mineral lands within the meaning of that term as used in statutes regulating the public lands, unless a contrary intention of Congress was clearly manifested. Whatever doubt there may be as to the effect of this declaration on past transactions, it is clear that after it was made coal lands were to be treated as mineral lands. That the land now in dispute was `known' coal land at the time it was selected, no one can doubt. It had been worked as a mine for many years before, and it had upon its surface all the appliances necessary for reaching, taking out, and delivering the coal. That Barnard knew what it was when he asked for its location for his use is absolutely certain, because he was one of the agents of the coal company at the time, and undoubtedly acted in its behalf in all that he did. If Mullan and Avery were ignorant of the fact when they acquired their respective interests in the property, it was because they wilfully shut their eyes to what was going on around them, and purposely kept themselves in ignorance of notorious facts. But the evidence satisfies us entirely that they were not ignorant.”
1 later decision quote this exact passage · from the majority“The patent is but evidence of a grant, and the officer who issues it acts ministerially and not judicially. If he issues a patent for land- reserved from sale by law, such patent is void for want of authority. But one officer of the land office is not competent to cancel or annul the act of his predecessor. • That is a judicial act, and requires the judgment of a court.”
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.