Frank v. Mangum’s Empirical Analysis
237 U.S. 309 · 1915
Citation profile
605 federal appellate · 137 district · 389 state decisions
How this case has been cited
Cited by 1,739 later decisions (196 by the Supreme Court) — most recently February 2025 · most notably Schneckloth v. Bustamonte (1973), Johnson v. Zerbst (1938)
605 federal appellate · 137 district · 389 state decisions — followed in 42 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 Pennoyer v. Neff · Hurtado v. People of the State of California · Chicago Co v. City of Chicago · Calder et Wife, v. Bull et Wife. · Diaz v. United States
Cited together with Moore v. Dempsey · Johnson v. Zerbst · Mooney v. Holohan · Fay v. Noia · Powell v. State of Alabama Patterson
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 1,739 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“although every form may have been preserved”
8 later decisions quote this exact passage · from the dissent““It is a fundamental principle of jurisprudence, arising from the very nature of courts of justice and the objects for which they are established, that a question of fact or of law distinctly put in issue and directly determined by a court of competent jurisdiction cannot afterwards be disputed between the same parties. Southern Pacific Railroad v. United States, 168 U. S. 1 , 48 [ 18 S. Ct. 18 , 42 L. Ed. 355 ]. The principle is as applicable to the decisions of criminal courts as to those of civil jurisdiction.””
7 later decisions quote this exact passage · from the majority“[t]his is not a matter for polite assumptions; we must look facts in the face.”
7 later decisions quote this exact passage · from the dissent
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.