Egle v. Constantin’s Empirical Analysis
1941
Citation profile
2 federal appellate · 26 state decisions
How this case has been cited
Cited by 32 later decisions — most recently December 1979 · most notably Quatre Parish Co. v. Beauregard Parish School Board (1952), Ewald v. Hodges (1960)
2 federal appellate · 26 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 Tillery v. Fuller · Griffing v. Taft · Ashley Co. v. Bradford · Pierson v. Castell Land & Harbor Co. · Close v. Rowan
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[11] Plaintiffs allege that defendants are in actual and physical possession of the lands claimed by them. Defendants aver that they acquired the lands by mesne conveyances from Maximillien Bernard, the purchaser at the tax sale on December 6, 1877, and that they and their ancestors in title have been in undisturbed possession of the lands since shortly after that date. Therefore, as between the parties there is no uncertainty as to the location and description of the property involved in this suit. (Emphasis added) “[12] The plaintiffs and their ancestors in title have stood by for years, silent and inactive, while Maxmillien Bernard and his successors in title were in possession of all these lands under a tax title and mesne conveyance and have permitted them to exercise all the rights of ownership in the land. In Harrell v. Harrell, 174 La. 957 , 142 So. 138, 140 , this Court, citing a number of authorities, said: 'It is well settled that: “The presumption ‘omnia rite’ applies to tax sales after parties have slept on their rights for many years.” ’ “In that case this Court also quoted approvingly from Griffing v. Taft, 151 La. 442 , 91 So. 832 , as follows: ‘Moreover, it is immaterial (for the purposes of prescription under article 233 of the Constitution of 1898) whether the assessment has been made in the name of one person, or another, or in no name, or whether the owner, not in possession, has been notified, or whether the sale has been advertised or has not been adve”
1 later decision quote this exact passagee.g. Gaudet v. Lawes“`It is scarcely necessary to repeat what this court has so often taken occasion to announce, that since the Constitution of 1879 and the succeeding ones [referring to those of 1898 and 1913], where there has been an assessment of land and a tax sale is made which describes the land in such a manner that it can be reasonably identified, the peremption of three years provided for by the Constitution applies, and the tax title is not subject to attack thereafter, except on the two grounds stated [referring to prior payment and dual assessment], or where the tax debtor, tax delinquent, or owner has remained in possession of the property after the said tax sale.'”
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.