Heike v. United States’s Empirical Analysis
217 U.S. 423 · 1910
Citation profile
155 federal appellate · 8 district · 36 state decisions
How this case has been cited
Cited by 262 later decisions (48 by the Supreme Court) — most recently May 2018 · most notably Murphy v. Waterfront Commission of New York Harbor (1964), Flanagan v. United States (1984)
155 federal appellate · 8 district · 36 state decisions — followed in 14 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 Counselman v. Hitchcock · Mills v. Green · Brown v. Walker · Burton v. United States · Alexander v. United States
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 262 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“not . . . to secure to a person making such a plea immunity from prosecution, but to provide him with a shield against successful prosecution, available to him as a defense”
5 later decisions quote this exact passage · from the majority“As the case now stands, upon the plea of not guilty, upon which the issue raised must be tried to a jury, certainly the whole matter has not been disposed of. It may be that upon trial the defendant will be acquitted on the merits. It may happen that for some reason the trial will never take place. In either of these events there can be no conclusive judgment against the defendant in the case. It is true that in a certain sense an order concerning a controlling question of law made in a case is, as to that question, final. Many interlocutory rulings, and orders effectually dispose of some matters in controversy, but that is not the test of finality for the purposes of appeal or writ of error. The purpose of the statute is to give a review in one proceeding after final judgment of matters in controversy in any given case. Any contrary construction of the Court of Appeals Act may involve the necessity of examining successive appeals or writs of error in the same case, instead of awaiting, as has been the practice since the beginning of the Government, for one review after a final judgment, disposing of all controversies in that case between the parties.”
4 later decisions quote this exact passage · from the majority““The same answer may be made to the suggestion that the witness is imperfectly protected by reason of the fact that he may still be prosecuted and put to the annoyance and expense of pleading his immunity by way of confession and avoidance. This is a detriment which the law does not recognize. There is a possibility that any citizen, however innocent, may be subjected to a civil or criminal prosecution and put to the expense of defending himself, but unless such prosecution be malicious he is remediless, except so far as a recovery of costs may partially indemnify him.” Heike v. U. S., 217 U. S. 423 -432, 30 S. Ct. 539, 542 ( 54 L. Ed. 821 ).”
2 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.