Miller v. Eagle Manuf'G Co’s Empirical Analysis
151 U.S. 186 · 1894
Citation profile
424 federal appellate · 148 district · 8 state decisions
How this case has been cited
Cited by 972 later decisions (13 by the Supreme Court) — most recently August 2024 · most notably Continental Paper Bag Company v. Eastern Paper Bag Company (1908), Pennwalt Corporation, Appellant/cross-Appellee v. Durand-Wayland, Inc., Appellee/cross-Appellant (1987)
424 federal appellate · 148 district · 8 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 Knapp v. Morss · Morley Sewing Machine Co. v. Lancaster · Merrill v. Yeomans · Roberts v. Ryer
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 972 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * it must distinctly appear that the invention covered by the later patent was a separate invention, distinctly different and independent from that covered by the first patent; in other words, it must be something substantially different from that comprehended in the first patent. It must consist in something more than a mere distinction of the breadth or scope of the claims of each patent.”
32 later decisions quote this exact passage · from the majority“[i]f the invention is broad and primary in its character, the range of equivalents will be correspondingly broad, under the liberal construction, which the courts give to such inventions.”
8 later decisions quote this exact passage · from the majority“In Miller v. Eagle Manufacturing Co., 151 U.S. 186 , 208, 14 S.Ct. 310, 319, 38 L.Ed. 121, the Court says on this subject: `The specific device described in and covered by the Wright patent could not be used in the appellants' combination, nor the appellants' spring in the appellee's combination. This interchangeability or noninterchangeability is an important test in determining the question of infringement.' 37”
3 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.