United States v. American Bell Telephone Co.’s Empirical Analysis
128 U.S. 315 · 1888
Citation profile
154 federal appellate · 45 district · 14 state decisions
How this case has been cited
Cited by 403 later decisions (48 by the Supreme Court) — most recently January 2025 · most notably Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation (1971), Hazel-Atlas Glass Co. v. Hartford-Empire Co. (1944)
154 federal appellate · 45 district · 14 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 Osborn v. President Directors and Company of the Bank of the United States · United States v. Lee · Ex parte McCardle · 'The Ku-Klux Cases' Yarbrough · Hawes v. Oakland
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 403 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“This language is construed by counsel for the appellee in this case to limit the relief granted at the instance of the United States to cases in which it has a direct pecuniary interest. But it is not susceptible of such construction. It was evidently in the mind of the court that the case before it was one where the property right to the land in controversy was the matter of importance, but it was careful to say that the cases in which the instrumentality of the court cannot thus be used are those where the United States has no pecuniary interest in the remedy sought, and is also under no obligation to the party who will be benefited to sustain an action for his use, and also where it does not appear that any obligation existed on the part of the United States to the public or to any individual. The essence of the right of the United States to interfere in the present case is its obligation to protect the public from the monopoly of the patent which was procured by fraud, and it would be difficult to find language more aptly used to include this in the class of cases which are not excluded from the jurisdiction of the court by want of interest in the government of the United States.”
4 later decisions quote this exact passage · from the majority“if it is apparent that the suit is brought for the benefit of some third party, and that the United States has no pecuniary interest in the remedy sought, and is under no obligation to the party who will be benefited . . . ; in short, if there does not appear any obligation on the part of the United States to the public, or to any individual, or any interest of its own, it can no more sustain such an action than any private person could under similar circumstance.”
3 later decisions quote this exact passage · from the majority““The principle of multifariousness is one very largely of convenience, and is more often applied where two parties are attempted to be brought together by a bill in chancery who have no common, interest in the litigation, whereby one party is compelled to join in the expense and trouble of a suit in which he and his codefendant have no common interest, or in which one party is joined as complainant with another party with whom in like manner he either has no interest at all, or no such interest as requires the defendant to litigate it in the same action. Oliver v. Piatt. 3 How. 333 [ 11 L. Ed. 622 ]; Walkers v. Powers, 164 U. S. 245 [ 26 L. Ed. 729 ].””
2 later decisions 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.