Underhill v. Hernandez’s Empirical Analysis
168 U.S. 250 · 1897
Citation profile
299 federal appellate · 95 district · 75 state decisions
How this case has been cited
Cited by 836 later decisions (41 by the Supreme Court) — most recently September 2024 · most notably Banco Nacional De Cuba v. Sabbatino (1964), Guaranty Trust Co of New York v. United States (1938)
299 federal appellate · 95 district · 75 state decisions — followed in 14 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.
Appellate journey
reviewedthe decision below (from Second Circuit Court of Appeals)
Relationships
Relies on Jones v. United States · The Three Friends · Thorington v. Smith · Williams v. Bruffy
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 836 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Every sovereign State is bound to respect the independence of every other sovereign State, and the courts of one country will not sit in judgment on the acts of the government of another done within its own territory.”
38 later decisions quote this exact passage“Every sovereign State is bound to respect the independence of every other sovereign State, and the courts of one country will not sit in judgment on the acts of the government of another done within its own territory. Redress of grievances by reason of such acts must be obtained through the means open to be availed of by sovereign powers as between themselves.”
36 later decisions quote this exact passage · from the majority“[t]he immunity of individuals from suits brought in foreign tribunals for acts done within their own states, in the exercise of governmental authority ... as civil officers”
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.