Steele v. Williams’s Empirical Analysis
1944
Citation profile
35 state decisions
How this case has been cited
Cited by 35 later decisions — most recently September 2018 · most notably Sandy Island Corp. v. Ragsdale (1965), Boyd v. BellSouth Telephone Telegraph Co. (2006)
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.
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.
“The fact that the words “heirs and assigns forever” were used [in the instrument creating the easement] does not and cannot change an easement in gross to an easement appurtenant to land. Even if it were admitted that the use of the words “heirs and assigns forever” connoted an intention of the parties to create an easement appurtenant to land, it would bring no advantage to the appellant. For to so do would contravene an established rule of law, and whatever may have been the intentions of the parties, it must yield to this rule of law so well established in this State.”
1 later decision quote this exact passage · from the majoritye.g. Ballington v. Paxton“Three things are necessary to establish a right by prescription: ... (3) that the use or enjoyment was adverse or under claim of right.”). The Court offered no explanation for dropping the comma. While the comma reappeared after the term”
1 later decision quote this exact passage · from the majority“An appendant or appurtenant easement must inhere in the land, concern the premises, have one terminus on the land of the party claiming it, and be essentially necessary to the enjoyment thereof.”
1 later decision quote this exact passage · from the majoritye.g. Springob v. Farrar
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.