Redfield v. Parks’s Empirical Analysis
132 U.S. 239 · 1889
Citation profile
35 federal appellate · 14 district · 56 state decisions
How this case has been cited
Cited by 141 later decisions (7 by the Supreme Court) — most recently June 1999 · most notably Chesapeake & Ohio Railway Co. v. Cockrell (1914), Light v. United States (1911)
35 federal appellate · 14 district · 56 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 De La Fayette Wilcox v. John Jackson · United States v. Thompson · Gibson v. Chouteau · Bagnell v. Broderick
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 141 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In the courts of the United States where the distinction between actions at law and suits in equity has always been maintained, the action of ejectment is an action at law ....”
2 later decisions quote this exact passage · from the majority““The principal issue in the case before [the lower] court was on the defense under the statute of limitations. The plaintiff relied upon, and introduced in evidence, a patent from the United States dated April 15, 1875, conveying the property to the Mississippi, Ouachita & Bed Kiver R. B. Co., reciting the purchase by that company of the land in controversy and the payment of §594.48 for it. The plaintiff, Redfield, purchased this land at a judicial sale, on a judgment against that company, for the sum of §500, and received a deed under that purchase. It further appears from the findings of the court that the railroad company made payment in full for the land September 10, 1856, and received at that time the certificate -of the register of the land office. The approval of this entry for the issue of a patent was made at the General Land Office in Washington, June 1, 1874. The circumstances under which the delay in the issue of a patent was had are not stated. The defendants relied upon a deed made by the county clerk of Lafayette county, Ark., to W. F. Parks and James M. Montgomery, on the 11th day • of August, 1871, upon a sale for taxes for the year 1868, and upon adverse possession under the statute of Arkansas of two years in regard to claims under tax sales, and the general statute of limitation of seven years. “This action was commenced by the plaintiff on the 11th day of April, 1882. The court entered the following conclusions of law: (1) That said tax deed to Parks an”
1 later decision quote this exact passage · from the majority““That the possession of the defendants does not bar the plaintiff’s action is a point too clear to admit of much controversy. It is a well-settled principle that the statute of limitations does not run against a state. If a contrary rule were sanctioned, it would only be necessary for intruders upon the public lands to maintain their possessions until the statute of limitations shall run; and then they would become invested with the title against the government, and all persons claiming under it. In this way the public domain would soon be appropriated by adventurers. Indeed, it would be utterly impracticable, by the use of any power within the reach of the government, to prevent this result. It is only necessary, therefore, to state the case in order to show the wisdom and propriety of the rule that the statute never operates against the government. The title under which the plaintiff in the ejectment claimed emanated from the government in 1824. Until this time there was no title adverse to the claim of the defendants; there can therefore be no bar to the plaintiff’s action.””
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.