Huse v. Glover’s Empirical Analysis
119 U.S. 543 · 1886
Citation profile
14 federal appellate · 18 district · 61 state decisions
How this case has been cited
Cited by 202 later decisions (47 by the Supreme Court) — most recently December 2019 · most notably Southern Pacific Co. v. Jensen (1917), Simpson v. Shepard (1913)
14 federal appellate · 18 district · 61 state decisions — followed in 19 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.
Appellate journey
Relationships
Relies on John Pollard et al. v. John Hagan et al. · Escanaba Lake Michigan Transp Co v. City of Chicago · Packet Company v. Keokuk · Parkersburg Ohio River Transp Co v. City of Parkersburg
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 202 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he exaction of tolls for passage through the locks is as compensation for the use of artificial facilities constructed[,] ... like charges for the use of wharves and docks constructed to facilitate the landing of persons and freight, and the taking them on board, or for the repair of vessels”
4 later decisions quote this exact passage · from the majority“The fact that if any surplus remains from the tolls, over what is used to keep the locks in repair, and for their collection, it is to be paid into the state treasury as a part of the revenue of the State, does not change the character of the toll or impost. * * * * * * Some disposition of the surplus is necessary until its use shall be required, and it may as well be placed in the state treasury, and probably better than anywhere else. Nor is there anything in the objection that the rates of toll are prescribed by the commissioners according to the tonnage of the vessels, and the amount of freight carried by them through the locks. This is simply a mode of fixing the rate according to the size of the vessel and the amount of property it carries, and in no sense is a duty of tonnage within the prohibition of the Constitution. & ¡fc Sfc # * “The fact that the rates (of wharfage) charged are graduated by the size or tonnage of the vessel is of no consequence in this connection. This does not make it a duty of tonnage in the sense of the Constitution and the Acts of Congress.” Cannon v. New Orleans, 20 Wall. 577 [ 22 L.Ed. 417 ]; Cincinnati, etc., Packet Co. v. Catlettsburg, 105 U.S. 559 , 26 L.Ed. 1169 (1882). It is unnecessary to pursue the subject further.”
1 later decision quote this exact passage · from the majority““The state is interested in the domestic as well as in the interstate and foreign commerce conducted on the Illinois river, and to increase its facilities, and thus augment its growth, it has full power. * * * If, in the opinion of the state, greater benefit would result to her commerce by the improvements made than by leaving tiie river in its natural state — and on that point the state must necessarily determine for itself — it may authorize them, although increased inconveniences and expense may thereby result to the business of individuals. The private inconvenience must yield to the public good. * * * How the highways of a state, whether on land or by water, shall be best improved for the public good, is a master for state determination, subject, always, to the right of Gongress to interpose in the cases mentioned.””
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.