Zartarian v. Billings’s Empirical Analysis
204 U.S. 170 · 1907
Citation profile
30 federal appellate · 20 district · 2 state decisions
How this case has been cited
Cited by 96 later decisions (11 by the Supreme Court) — most recently May 2021 · most notably Leng May Ma v. Barber (1958), Moser v. United States (1951)
30 federal appellate · 20 district · 2 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 United States v. Wong Kim Ark · Nishimura Ekiu v. United States · United States v. Ju Toy · Isabella Gonzales v. William Williams · Boyd v. Nebraska ex rel. Thayer
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 96 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The construction of this law and the meaning of the phrase ‘dwelling in the United States’ has been the subject of much consideration in the executive department of the government having to do with the admission of foreigners and the rights of alleged naturalized citizens of the United States. The rulings of the State Department are collected in Prof. Moore’s Digest of International Law, vol. 3, p. 467 et seq. The department seems to have followed a rule established at an early period, and formulated with fullness in Foreign Relations for 1890, p. 301, in an instruction from Mr. Blaine to Minister Phelps, at Berlin, in which it was laid down that the naturalization of the father operates to confer the municipal right of citizenship upon the minor child if,' at the time of the father’s naturalization, dwelling within the jurisdiction of the United States, or if he come within that jurisdiction subsequent to the father’s Naturalization and during his own minority.””
1 later decision quote this exact passage · from the majority“[A] child born without the United States of alien parents shall be deemed a citizen of the United States by virtue of the naturalization of ... the parent: Provided, That such naturalization or resumption takes place during the minority of such child; And provided further, That the citizenship of such minor child shall begin at the time such minor child begins to reside permanently in the United States.”
1 later decision quote this exact passage · from the majoritye.g. Nwozuzu v. Holder““It is pointed out by Mr. Justice Gray, delivering the opinion in United States v. Wong Kim Ark, 169 U. S. 649 -686, 18 Sup. Ct. 456 , 42 L. Ed. 890 , that the naturalization acts of the United States have been careful to limit admission to citizenship to those ‘within the limits and under the jurisdiction of the United States.’””
1 later decision quote this exact passage · from the majoritye.g. In re Rustigian
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.