Northern Pacific Railway Company v. Jacob Slaght’s Empirical Analysis
205 U.S. 122 · 1907
Citation profile
88 federal appellate · 29 district · 49 state decisions
How this case has been cited
Cited by 233 later decisions (9 by the Supreme Court) — most recently September 2019 · most notably Bigelow v. Old Dominion Copper Mining & Smelting Co. (1912), Riehle v. Margolies (1929)
88 federal appellate · 29 district · 49 state decisions — followed in 17 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.
Relationships
Relies on Cromwell v. County of Sac · Southern Pacific Railroad v. United States · Noble v. Union River Logging Railroad · Gunter v. Atlantic Coast Line Railroad · Knight v. United Land Ass'n
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 233 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Hatchitt v. United States, 158 F.2d 754 , 757 (9th Cir. 1946). “[The plaintiff] again asserts title to the very property that was the subject of the other suit, the source of title, only, being different. If this may be done, how often may it be repeated? If defeated upon the new title, may plaintiff in error assert still another one, either in its predecessor or in itself, and repeat as often as it may vary its claim? The principle of res judicata and the cases enforcing and illustrating that principle declare otherwise.””
4 later decisions quote this exact passage · from the majority““Although there may be several different claims for the same thing, there can be only one right of property in it; therefore, when a cause of action has resulted in favor of the defendant, when the plaintiff claims the property of a certain thing there can be no> other action maintained against the same party for the same property, for that would be to renew the question already decided; for the single question in litigation was whether the property'belonged to the plaintiff or not; and it is of no importance that the plaintiff failed to set up all his rights upon which his cause of action could have been maintained; it is sufficient that it might have been litigated.””
2 later decisions quote this exact passage · from the majority““The best that can be said, apart from the act just quoted, to distinguish the two suits, is that now the United States puts forward a new ground for its prayer. Formerly it sought to avoid the patents by way of forfeiture. Now it seeks the same conclusion by a different means; that is to say, by evidence that the lands originally were excepted from the grant. But in this, as in the former suit, it seeks to establish its own title to the fee.””
1 later decision 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.