Mt Vernon-Woodberry Cotton Duck Company v. Alabama Interstate Power Company’s Empirical Analysis
240 U.S. 30 · 1916
Citation profile
15 federal appellate · 4 district · 60 state decisions
How this case has been cited
Cited by 138 later decisions (22 by the Supreme Court) — most recently July 2021 · most notably Utah Power Light Company v. United States No 202 United States (1917), Rescue Army v. Municipal Court of Los Angeles (1947)
15 federal appellate · 4 district · 60 state decisions — followed in 15 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 Plowden Weston v. The City Council of Charleston · Clark v. Nash · Strickley v. Highland Boy Gold Mining Co. · Hairston v. Danville & Western Railway 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 138 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The principal argument presented that is open here, is that the purpose of the condemnation is not a public one. The purpose of the Power Company’s incorporation, and that for which it seeks to condemn property of the plaintiff in error, is to manufacture, supply, and sell to the public, power produced by water as a motive force. . . . We perceive no ground for the distinction attempted between the taking of rights below the contemplated dam, such as these are, and those above. Compensation is provided for according to rules that the court below declares to be well settled and that appear to be adequate. . . .” (Emphasis supplied.)”
1 later decision quote this exact passage · from the majority““In the organic relations of modern society it may sometimes be hard to draw the line that is supposed to limit the authority of the Legislature to exercise or delegate the power of eminent domain. But to gather the streams from waste and to draw from them energy, labor without brains, and so to save mankind from toil that it can be spared, is to supply ■what, next to intellect, is the very foundation of all our achievements and all our welfare. If that purpose is not public we should be at a loss to say what is. The inadequacy of use by the general public as a universal test is established.””
1 later decision quote this exact passage · from the majoritye.g. Harvey v. Warren
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.