In re Eckart’s Empirical Analysis
166 U.S. 481 · 1897
Citation profile
59 federal appellate · 9 district · 38 state decisions
How this case has been cited
Cited by 154 later decisions (14 by the Supreme Court) — most recently June 2023 · most notably Knewel v. Egan (1925), Clark v. Arizona (2006)
59 federal appellate · 9 district · 38 state decisions — followed in 17 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 United States v. Pridgeon · Coy · Bigelow · Ex Parte Belt
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 154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In its decision refusing the writ applied for by Eckart, the supreme court of Wisconsin held that while the conviction under the sentence in question was erroneous, the error in passing sentence was not a jurisdictional defect, and the judgment was therefore not void. In this view we concur. The court had jurisdiction of the offence charged and of the person of the accused. The verdict clearly did not acquit him of the crime with which he was charged, but found that he had committed an offence embraced within the accusation upon which he was tried. It was within the jurisdiction of the trial judge to pass upon the sufficiency of the verdict, and to construe its legal meaning, and if, in so doing, he erred, and held the verdict to be sufficiently certain to authorize the imposition of punishment for the highest grade of the offence charged, it was an error committed in the exercise of jurisdiction, and one which does not present a jurisdictional defect, remediable by the writ of habeas corpus.””
6 later decisions quote this exact passage · from the majority““It has been held by the supreme court of Wisconsin that, under the statutes of that state, an allegation of the commission of crime in language such as was employed in the information upon which Eckart was tried would justify a conviction of murder in either the first, second, or third degree, and it has also been there held that the jury must find the degree in their verdict in order that the court may impose the proper punishment. * * *.””
1 later decision quote this exact passage · from the majoritye.g. Moore v. Buchkoe
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.