United States v. Angeline Lombardo’s Empirical Analysis
241 U.S. 73 · 1916
Citation profile
274 federal appellate · 87 district · 103 state decisions
How this case has been cited
Cited by 851 later decisions (34 by the Supreme Court) — most recently June 2025 · most notably Houston v. Lack (1988), Murphy v. Waterfront Commission of New York Harbor (1964)
274 federal appellate · 87 district · 103 state decisions — followed in 23 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 Gates v. . State · Hoyt v. Stark · United States v. Lombardo · In re Von Borcke
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 851 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“is not complete until the document is delivered and received.”
30 later decisions quote this exact passage · from the majority“`[W]here a crime consists of distinct parts which have different localities the whole may be tried where any part can be proved to have been done.'”
10 later decisions quote this exact passage · from the majority““A court is constrained by the meaning of the words of a statute. They mark the extent of its power, and our attention has not been called to any case which decides that the requirement of a statute, whether to secure or preserve a right or to avoid the guilt of a crime, that a paper shall be filed with a particular officer, is satisfied by a deposit in the post-office at some distant place. To so hold would create revolutions in the procedure of the law and the regulation of rights. In instances it might, indeed, be convenient; in others, and most others, it would result in confusion and controversies; and we would have the clash of oral testimonies for the certain evidence of the paper in the files. We hesitate, in order to accommodate the venue of a particular offense, to introduce such confusion. And would it not, besides, in particular cases, preclude the possibility of a conviction, putting evidence entirely in the hands of the defendant?””
7 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.