Frost v. Spitley’s Empirical Analysis
121 U.S. 552 · 1887
Citation profile
77 federal appellate · 23 district · 48 state decisions
How this case has been cited
Cited by 243 later decisions (23 by the Supreme Court) — most recently December 1954 · most notably Heckman v. United States (1912), Whitehead v. Shattuck (1891)
77 federal appellate · 23 district · 48 state decisions — followed in 15 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 Van Brocklin v. Anderson · Holland v. Challen · Van Wyck v. Knevals · Reynolds v. First Nat Bank of Crawfordsville Indiana
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 243 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Under the jurisdiction and practice in equity, independently of statute, the object of a bill to remove a cloud upon title, and to quiet the possession of real estate, is to protect the owner of the legal title from being disturbed in his possession, or harassed by suits in regard to that title; and the bill cannot be maintained without clear proof of both possession and legal title in the plaintiff. Alexander v. Pendleton, 8 Cranch, 462 [ 3 L. Ed. 624 ]; Peirsoll v. Elliott, 6 Pet. 95 [ 8 L. Ed. 332 ]; Orton v. Smith, 18 How. 263 [ 15 L. Ed. 393 ]; Crews v. Burcham, 1 Black, 352 [ 17 L. Ed. 91 ]; Ward v. Chamberlain, 2 Black, 430 [ 17 L. Ed. 319 ]. As observed by Mr. Justice Grier in Orton v. Smith: ‘Those only who have a clear legal and equitable title to land, connected with possession, have any right to claim the interference of a court of equity to give them peace or dissipate a cloud upon the title.’ 18 How. 265 . A person out of possession cannot maintain such a bill, whether his title is legal or equitable, for, if his title is legal, his remedy at law, by action of ejectment, is plain, adequate, and complete, and, if his title is equitable, he must acquire the legal title, and then bring ejectment. United States v. Wilson, 118 U. S. 86 [ 6 Sup. Ct. 991 , 30 L. Ed. 110 ]; Fussell v. Gregg, 113 U. S. 550 [ 5 Sup. Ct. 631 , 28 L. Ed. 993 ].””
7 later decisions quote this exact passage · from the majority““It is obvious, therefore, that, if that deed did not pass the legal title, the appellant is without standing in eourt; for although, under the laws of Mississippi (Code 1892, § 500), a bill may be maintained in the circuit court of the United States by a person not in possession against another who is also out of possession, as is the case here, ‘still this does not make the complainant’s rights any the less dependent upon title in him, nor does it put him in a position to have a cloud removed from a title which has no existence.””
3 later decisions quote this exact passage · from the majority““The requisite of the plaintiff’s possession is thus dispensed with, but not the other rules which govern the jurisdiction of courts of equity over such bills. Under that statute, as under the general jurisdiction in equity, it is ‘the title,’ that is to say, the -legal title, to real estate, that is to be quieted against claims of adverse estates or interests.” .”
1 later decision quote this exact passage · from the majoritye.g. Stanton v. Catron
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.