Noble v. Union River Logging Railroad’s Empirical Analysis
147 U.S. 165 · 1893
Citation profile
224 federal appellate · 38 district · 103 state decisions
How this case has been cited
Cited by 651 later decisions (111 by the Supreme Court) — most recently April 2023 · most notably Pennhurst State School and Hospital v. Halderman (1984), Larson v. Domestic & Foreign Commerce Corp. (1949)
224 federal appellate · 38 district · 103 state decisions — followed in 26 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 William Marbury v. James Madison · Pennoyer v. Neff · Seymour v. Osborne · Sawyer
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 651 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is true that, in every proceeding of a judicial nature, there are one or more facts which aré strictly jurisdictional, the existence of which is necessary to the validity of the proceedings, and without which the act of the court is a mere nullity. * * * “There is, however, another class of facts which are termed ‘quasi jurisdictional,’ which are necessary to be alleged and proved in order to set the machinery of the law in motion, but which, when properly alleged, and established to the satisfaction of the court, cannot be attacked collaterally. With respect to these facts, the finding of the court is as conclusively presumed to be correct as its finding with respect to any other matter in issue between the parties. * * * “This distinction has been taken in a large number of cases in this court, in which the validity of land patents has been attacked collaterally, and it has always been held that the existence of lands subject to be patented was the only necessary prerequisite to a valid patent. In the one class of cases it is held that, if the land attempted to be patented had been reserved, or was at the time no part of the public domain, the land department had no jurisdiction over it, and no power or authority to dispose of it. In such cases its action in certifying'the lands under a railroad grant, or in issuing a patent, is not merely irregular, but absolutely void, and may be shown to be so in - any collateral proceeding. * * * “Upon the other hand, if the patent ”
6 later decisions quote this exact passage · from the majority“"The railroad company became at once vested with the right of property in these lands, of which they can only be deprived by proceedings taken directly for that purpose. If it were made to appear that the right of way had been obtained by fraud, a bill would doubtless lie by the United States for the cancellation and annulment of an approval thus obtained.””
5 later decisions quote this exact passage · from the majority“It is true that, in every proceeding of a judicial nature, there are one or more facts which are strictly jurisdictional, the existence of which is necessary to the validity of the proceedings, and without which the act of the court is a mere nullity; such, for example, as * * * the seizure and possession of the res within the bailiwick in a proceeding in rem * * *. In these and similar cases the action of the court * * * fails for want of jurisdiction over the person or subject-matter. The proceeding is a nullity, and its invalidity may be shown in a collateral proceeding.”
4 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.