Metropolitan Co v. District of Columbia’s Empirical Analysis
132 U.S. 1 · 1889
Citation profile
76 federal appellate · 56 district · 136 state decisions
How this case has been cited
Cited by 340 later decisions (21 by the Supreme Court) — most recently March 2026 · most notably Guaranty Trust Co of New York v. United States (1938), Chattanooga Foundry & Pipe Works v. City of Atlanta (1906)
76 federal appellate · 56 district · 136 state decisions — followed in 24 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 Barnes v. District of Columbia · William M'Cluny v. Wyllis Silliman · Carrol v. Green · Hepburn & Dundas v. Ellzey
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 340 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"It is undoubtedly true that the District of Columbia is a separate political community in a certain sense [for diversity purposes], and in that sense may be called a State; but the sovereign power of this qualified State is not lodged in the corporation of the District of Columbia, but in the government of the United States. Its supreme legislative body is Congress. The subordinate legislative powers of a municipal character, which have been or may be lodged in the city corporations, or in the District Corporation, do not make those bodies sovereign. Crimes committed in the District are not crimes against the District, but against the United States. . . ." [ Id. at 9 , 10 S.Ct. at 22 .]”
5 later decisions quote this exact passage“We think ... that the [lower] court is in error in supposing that the present action is founded on the statute. It is an action on the case upon an implied as-sumpsit arising out of the defendant’s breach of a duty imposed by statute, and the required performance of that duty by the plaintiff in consequence. This raised an implied obligation on the part of the defendant to reimburse and pay to the plaintiff the moneys expended in that behalf. The action is founded on this implied obligation, and not on the statute, and is really an action of assumpsit. The fact that the duty which the defendant failed to perform was a statutory one does not make the action one upon the statute.”
3 later decisions quote this exact passage“It is just as much for the public interest and tranquility that municipal corporations should be limited in the time of bringing suits as that individuals or private corporations should be.”
3 later decisions quote this exact passage
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.