Parks v. Lyons’s Empirical Analysis
1938
Citation profile
35 state decisions
How this case has been cited
Cited by 35 later decisions — most recently December 1984 · most notably Payne, County Treas. v. Jones (1944), Welborn v. Whitney (1942)
35 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 Lind v. Stubblefield · Wade v. Crouch and Edwards · Keller v. Hawk · Campbell v. McGrath · Davenport v. Doyle
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Being enacted in the same act, they should be construed together, and when construed together, we think it is plain that they require the tender to be made when the action is commenced, or the pleading is filed, assailing the deed; . . . they require a tender of all taxes, interest, penalties, costs and expenses. Under section 12668, supra, (68 O. S. 1941 § 360) it is the duty of the court to require the amount due to be paid before the judgment is made effective.””
2 later decisions quote this exact passage““ * * * when his action to set aside the tax deed is brought, or a defense to a recovery of possession is plead, tender in open court for the use of the holder of the tax deed, all taxes, penalties, interest and costs, which the party seeking to redeem would be bound to pay if he was then redeeming the land from tax sale, * ■* *.””
2 later decisions quote this exact passage““Under sections 12761 and 12763, O. S. 1931 (68 Okla. St. Ann. §§ 453 and 455), a defendant asking affirmative relief against a tax deed must, in his cross-petition • or answer attacking the deed, tender all the taxes, interest, penalty, costs and expenses assessed against the land. The tender is required in all cases where the land is liable for taxation, has been assessed and extended upon tax rolls in substantial compliance with the statutes, and the taxes have not been paid. Under such circumstances, the tender must be made whether the tax deed is void on its face, void for jurisdictional reasons, voidable or valid; and under such circumstances it is the duty of the court to require the payment of-the amount due against the land as a condition precedent to entering judgment invalidating the tax deed.””
1 later decision quote this exact passagee.g. Tischer v. Arrington
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.