United States v. J a Reynolds’s Empirical Analysis
235 U.S. 133 · 1914
Citation profile
29 federal appellate · 17 district · 37 state decisions
How this case has been cited
Cited by 128 later decisions (12 by the Supreme Court) — most recently May 2016 · most notably Near v. State of Minnesota Olson (1931), United States v. Kozminski (1988)
29 federal appellate · 17 district · 37 state decisions — followed in 12 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 Siler v. Louisville & Nashville Railroad · Hagar v. · Hardin v. Jordan · Alonzo Bailey v. State of Alabama · Fallbrook Irrigation District v. Bradley
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 128 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The holding of any person to service or labor under the system known as peonage is abolished and forever prohibited in any Territory or State of the United States; and all acts, laws, . . . regulations, or usages of any Territory or State, which have heretofore established, . . . or by virtue of which any attempt shall hereafter be made to establish, maintain, or enforce, directly or indirectly, the voluntary or involuntary service or labor of any person as peons, in liquidation of any debt or obligation, or otherwise, are declared null and void.””
4 later decisions quote this exact passage · from the majority“It may be defined as a status or condition of compulsory service, based upon the indebtedness of the peon to the master. The basal fact is indebtedness____ Upon this is based a condition of compulsory service. Peonage is sometimes classified as voluntary or involuntary, but this implies simply a difference in the mode of origin, but none in character of the servitude. The one exists where the debtor voluntarily contracts to enter the service of his creditor. The other is forced upon the debtor by provision of some law. But peonage, however created, is compulsory service, involuntary servitude. The peon can release himself therefrom, it is true, by the payment of the debt, but otherwise the service is enforced. A clear distinction exists between peonage and the voluntary performance of labor or rendering of services in payment of a debt. In the latter case the debtor, though contracting to pay his indebtedness by labor or service, and subject like any other contractor to an action for damages for breach of that contract, can elect at any time to breach it, and no law or force compels performance or a continuation of the service.”
2 later decisions quote this exact passage · from the majority““Neither slavery nor involuntary servitude, except as a punishment for crime whereof the party shall have been duly convicted, shall exist within the United States, or any place subject to their jurisdiction.””
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.