Waskey v. Chambers’s Empirical Analysis
224 U.S. 564 · 1912
Citation profile
8 federal appellate · 5 district · 20 state decisions
How this case has been cited
Cited by 38 later decisions (4 by the Supreme Court) — most recently December 1974 · most notably Commonwealth v. Monumental Properties, Inc. (1974), United States v. Southern Pacific Co. (1922)
8 federal appellate · 5 district · 20 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.
Appellate journey
reviewedAlaska Exploration Co. v. Northern Mining & Trading Co. (from Ninth Circuit Court of Appeals)
Relationships
Relies on Alaska Exploration Co. v. Northern Mining & Trading Co.
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The Circuit Court of Appeals went on the ground that a lease creates only a chattel interest and is not a conveyance, and therefore is not within the protection of the statute. But it is obvious that in principle the right of a lessee is the same as that of a purchaser in fee, and it would be a great misfortune, especially to mining interests, if a man taking a lease from those whom the record showed and he believed to be the owners, were liable, after spending large sums of money on the faith of it, to be turned out by, an undisclosed claimant on the strength of an unrecorded deed. We find no words in the statute that require such a result. On the contrary, the word ‘conveyance’ is defined although for other purposes, as embracing every written instrument except a will by which any interest in lands is created. Act 1900, tit. 3, § 136, 31 Stat. 510 ; Code, part V, § 136. See title 2, § 1046, 31 Stat. 493 ; Code, part IV, § 1046. And the statute provides for the recording of leases, as well as of deeds and grants. Act 1900, tit. 1, § 15, 31 Stat. 327 ; Code, part III, § 15. Blackstone defines a lease as a conveyance. 2 Comm. 317. And in Shepard’s Touchstone, 267, leases are ranked under the head of grants — ‘as in other grants.’ The point does not need authority, except to exclude the notion that the statute uses the word in a narrower sense. * * * “Waskey was in possession and at work before the deed to Chambers was filed for recording; but we do not have to consider whethe”
4 later decisions quote this exact passage · from the majority““Every conveyance of real property within the district hereafter made which shall not be filed for record as provided in this chapter shall be void against any subsequent innocent purchaser in good faith and for a valuable consideration of the same real property, or any portion thereof, whose conveyance shall be first duly recorded.””
1 later decision quote this exact passage · from the majoritye.g. Parks v. Parks
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.