Ownbey v. Morgan’s Empirical Analysis
256 U.S. 94 · 1921
Citation profile
68 federal appellate · 57 district · 175 state decisions
How this case has been cited
Cited by 512 later decisions (65 by the Supreme Court) — most recently December 2023 · most notably Parratt v. Taylor (1981), Fuentes v. Shevin (1972)
68 federal appellate · 57 district · 175 state decisions — followed in 32 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 · Royster Guano Co v. Commonwealth of Virginia · Connolly v. Union Sewer Pipe Co. · 'The Ku-Klux Cases' Yarbrough · Gulf Ry Co v. Ellis
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 512 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] procedure customarily employed, long before the Revolution, in the commercial metropolis of England, and generally adopted by the States as suited to their circumstances and needs, cannot be deemed inconsistent with due process of law.”
4 later decisions quote this exact passage · from the majority““. . . it cannot rightly be said that the Fourteenth Amendment furnishes a universal and self-executing remedy. Its function is negative, not affirmative, and it carries no mandate for particular measures of reform. . . .””
4 later decisions quote this exact passage · from the majority““The due process clause does not impose upon the states a duty to establish ideal systems for the administration of justice, with every modern improvement and with provision against every possible hardship that may befall. It restrains state action, whether legislative, executive, or judicial, within the bounds that are consistent with the fundamentals of individual liberty and private property, including the right to be heard where liberty or property is at stake in judicial proceedings. But a property owner who absents himself from the territorial jurisdiction of a state, leaving his property within it, must be deemed ex necessitate to consent that the state may subject such property to judicial process to answer demands made against him in his absence, according to any practicable method that reasonably may be adopted.””
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.