Bessette v. W. B. Conkey Co.’s Empirical Analysis
194 U.S. 324 · 1904
Citation profile
259 federal appellate · 43 district · 214 state decisions
How this case has been cited
Cited by 726 later decisions (105 by the Supreme Court) — most recently January 2025 · most notably United States v. United Mine Workers of America (1947), Gompers v. Bucks Stove & Range Co. (1911)
259 federal appellate · 43 district · 214 state decisions — followed in 37 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 Seventh Circuit Court of Appeals)
Relationships
Relies on In re Debs · The Paquete Habana · Ex parte Robinson · Fisk
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 726 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“it may not always be easy to classify a particular act as belonging to either one of these two classes. It may partake of the characteristics of both.”
11 later decisions quote this exact passage · from the majority““Proceedings for contempts are of two classes: Those prosecuted to preserve the power and vindicate the dignity of the courts and to punish for disobedience of their orders, and those instituted to preserve and enforce the rights of private parties to suits and to compel obedience to orders and decrees made to enforce the rights and administer the remedies to which the court has found them to be entitled. The former are criminal and punitive in their nature, and the government, the courts, and the people are interested in their prosecution. The latter are civil, remedial, and coercive in their nature, and the parties chiefly in interest in their conduct and prosecution are the individuals whose private rights and remedies they were instituted to protect or enforce. * * * A criminal contempt involves no element of personal injury. It is directed against the power and dignity of the court, and private parties have little, if any, interest in the proceedings for its punishment. But if the contempt consists in the refusal of a party or a person to do an act which the court has ordered him to do for the benefit or the advantage of a party to a suit or action' pending before it, and he is committed until he complies with the order, the commitment is in the nature of an execution to enforce the judgment of the court, and the party in 'whose favor that judgment was rendered is the real party in interest in the proceedings.””
7 later decisions quote this exact passage · from the majority“A court of the United States shall have power to punish by fine or imprisonment, at its discretion, such contempt of its authority, and none other, as ****** (3) Disobedience or resistance to its lawful writ, process, order, rule, decree, or command.”
5 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.