Joseph Guffey v. James a Smith’s Empirical Analysis
237 U.S. 101 · 1915
Citation profile
125 federal appellate · 41 district · 119 state decisions
How this case has been cited
Cited by 354 later decisions (20 by the Supreme Court) — most recently January 2022 · most notably Angel v. Bullington (1947), Pusey & Jones Co. v. Hanssen (1923)
125 federal appellate · 41 district · 119 state decisions — followed in 20 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
reviewedSmith v. Guffey (from Seventh Circuit Court of Appeals)
Relationships
Relies on Swift v. Tyson · Burgess v. Seligman · Twin-Lick Oil Company v. Marbury · Payne v. Hook · Ohio Oil Company v. State of Indiana
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 354 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Bightly understood, this "is not a suit for specific performance. Its purpose is not to enforce an executory contract to give a lease, or even to enforce an executory promise in a lease already given, but to protect a present vested leasehold, amounting to a freehold interest, from continuing an irreparable injury calculated to accomplish its practical destruction. The complaint is not that performance of some promised act is being withheld or refused, hut that complainants’ vested freehold right is being wrongfully violated and impaired in a way which calls for preventive relief. In this respect the case is not materially different from what it would be if the complainants were claiming under an absolute conveyance rather than a lease. In a practical sense this suit is one to prevent waste.””
4 later decisions quote this exact passage · from the majority““It is settled by the decisions of the Supreme Court of Illinois that an oil and gas lease like that of the complainants [italics mine] passes to the lessee, his heirs and assigns, a present vested right — ‘a freehold interest’ — in the premises, that this interest is taxable as real property, and that the clause giving the lessee an option to surrender the lease at any time is valid, does not create a tenancy at will, or give the lessor an option to compel a surrender, and does not make the lease void as wanting in mutuality.””
3 later decisions quote this exact passage · from the majority““[T]he constructive notice resulting from the recording of the prior lease was not inconsistent with an honest, though mistaken, belief on their [defendants’] part that they had acquired a perfect right to take and dispose of the oil. But the expenses incurred after August 1, 1907, are upon a different footing. On that date Solley and his associates were actually and fully informed of the prior lease and of the complainants’ purpose to insist upon the rights conferred by it and to obtain redress for the invasion of those rights, so what was done thereafter cannot be regarded as anything less than a wilful taking and appropriation of the oil which was subject to the complainants’ superior right.” ( 237 U.S. 101, 118-19 , 59 L. Ed. 2d 856 , 866, 35 S. Ct. 526 , 531-32.)”
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.