Heckman v. United States’s Empirical Analysis
224 U.S. 413 · 1912
Citation profile
364 federal appellate · 82 district · 95 state decisions
How this case has been cited
Cited by 788 later decisions (107 by the Supreme Court) — most recently February 2022 · most notably Arizona v. California (1983), Moe v. Confederated Salish & Kootenai Tribes of the Flathead Reservation (1976)
364 federal appellate · 82 district · 95 state decisions — followed in 10 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.
Appellate journey
reviewedUnited States v. Allen (from Eighth Circuit Court of Appeals)
Relationships
Relies on United States v. Kagama · Samuel Worcester v. The State of Georgia · In re Debs · William Shields v. Robert R Barrow · The Cherokee Nation v. The State of Georgia
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 788 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““All restrictions upon the alienation of lands of all allottees of either of the Five Civilized Tribes of Indians who are not of Indian blood, except minors, are, except as to homesteads, hereby removed, and all restrictions upon the alienation of all other allottees of said Tribes, except minors, and except as to homesteads, may, with the approval of the Secretary of the Interior, be removed, etc.””
9 later decisions quote this exact passage“[djuring the continuance of this guardianship, the right and duty of the [United States] to enforce by all appropriate means the restrictions designed for the security of the Indians cannot be gainsaid.... ... A transfer of the [Indian land] is not simply a violation of the proprietary rights of the Indian. It violates the governmental rights of the United States....”
7 later decisions quote this exact passage · from the majority““The effectiveness of the acts of Congress is not thus to be destroyed. The restrictions were set forth in public laws, and were mat-^ ters of general knowledge. Those who dealt with the Indians contrary to these provisions are not entitled to insist that they should keep the land if the purchase price is not repaid, and thus frustrate the policy of the statute.””
7 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.