Hanrick v. Patrick’s Empirical Analysis
119 U.S. 156 · 1886
Citation profile
31 federal appellate · 4 district · 56 state decisions
How this case has been cited
Cited by 116 later decisions (11 by the Supreme Court) — most recently January 1970 · most notably Winters v. United States (1908), Gormley v. Clark (1890)
31 federal appellate · 4 district · 56 state decisions — followed in 21 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 Forgay v. Conrad · Brant v. Virginia Coal and Iron Company et al. · Jeremian Van Rensselaer v. Philip Kearney · Masterson v. Herndon
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 116 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The conveyance and the covenants are both confined to the right, title and interest which Eliza M. O’Brien had at the date of the deed, expressly referred to and described in the deed of February 1, 1878, as the interest conveyed by the deed from Jenkins. There is no recital in the deed to estop her as to the character of her title or the quantum of interest intended to be conveyed within the rule laid down by this court in Van Renssalear v. Kearney, 11 How. 297 . In the absence of such recital, a covenant of general warranty, where the estate granted is ‘ the present interest and title of the grantor, does not operate as an estoppel to pass a subsequently acquired title.””
1 later decision quote this exact passage · from the majoritye.g. Reed v. Whitney““ ‘Where a deed purports to convey only the right, title and interest of the grantor, the scope of the covenant of warranty may be limited by the subject-matter of the conveyance’. 2 Devlin on Deeds, sec. 931 and cases cited. Tiede-man on Real Property, sec. 858, says: ‘If a deed purports to convey in terms the right, title and interest of the grant- or to the land described, instead of conveying in terms the land itself, a general covenant of warranty will be limited to that right or interest, and will not be broken by the enforcement of a paramount title outstanding against the grantor at the time of the conveyance’.””
1 later decision quote this exact passage · from the majoritye.g. Reed v. Whitney“At any rate, the presumption was that the erasure was made before the execution of the deed.”
1 later decision quote this exact passage · from the majoritye.g. Wicker v. . Jones
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.