Melton v. Sneed’s Empirical Analysis
1940
Citation profile
2 federal appellate · 34 state decisions
How this case has been cited
Cited by 38 later decisions — most recently November 2012 · most notably Ricks Exploration Co. v. Oklahoma Water Resources Board (1984), 2 Ill. 2d 223 - Miller v. Ridgley (1954)
2 federal appellate · 34 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 3 Cal. 2d 110 - Callahan v. Martin · Rich v. Doneghey · Burns v. Bastien · Carroll v. Bowen · Wilson v. Olsen
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Where a deed conveyed, in perpetuity, ‘one-third of all royalties from oil, gas, or other minerals, arising from or out of or produced upon’ the lands described, and did not refer to any lease then existing on such land, the deed was ambiguous and the trial court properly permitted the introduction of evidence to ascertain the intent of the parties, and gave to such language the meaning which the parties intended, and held the instrument a grant of the minerals rather than a conveyance of the royalties only.””
2 later decisions quote this exact passage““4. Plaintiffs next assert that the trial court made a new contract between the parties when it held a conveyance of royalty to be a conveyance of mineral rights under their lands, and that this was in excess of the power of the court. This contention is based upon the strict construction of the word ‘royalty’. Carroll v. Bowen, 180 Okl. 215 , 68 P.2d 773 . But upon examination of the conveyance it is readily apparent that the word was not used in its strict sense, but in the broader sense referred to in 3 Summers Oil & Gas, Perm. Ed., § 599, as denoting an interest in the minerals. That the word is frequently used in this State to denote an interest in the mineral rights is a matter of common knowledge. The conveyance in • question here employed it in that sense.””
1 later decision quote this exact passage“In the absence of language indicating a contrary intent, a grant of such incidental rights as are essential to the full enjoyment of the property conveyed will be implied.”
1 later decision quote this exact passage
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.