Cox v. Hart’s Empirical Analysis
260 U.S. 427 · 1922
Citation profile
120 federal appellate · 52 district · 222 state decisions
How this case has been cited
Cited by 518 later decisions (35 by the Supreme Court) — most recently April 2024 · most notably Landgraf v. USI Film Products (1994), Springer v. Government of the Philippine Islands Agoncillo (1928)
120 federal appellate · 52 district · 222 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.
Appellate journey
reviewedCox v. Hart (from Ninth Circuit Court of Appeals)
Relationships
Relies on United States v. Trans-Missouri Freight Ass'n · Lessee James Ewing v. Jacob Burnet · Georgia Railroad & Banking Co. v. Smith · White v. United States
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 518 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A statute is not made retroactive merely because it draws upon antecedent facts for its operation.”
14 later decisions quote this exact passage · from the majority“The office of a proviso is well understood. It is to except something from the operative effect, or to qualify or restrain the generality, of the substantive enactment to which it is attached.”
2 later decisions quote this exact passage · from the majority“A survey of public lands does not ascertain boundaries; it creates them.... [The running of lines in the field and the laying out and platting of townships, sections and legal subdivisions are not alone sufficient to constitute a survey. Until all conditions as to filing in the proper land office and all requirements as to approval have been complied with, the lands are to be regarded as unsurveyed and not subject to disposal as surveyed lands.... In other words, to justify the application of the term 'surveyed' to a body of public land something is required beyond the completion of the field work and the consequent laying out of the boundaries, and that something is the filing of the plat and the approval of the work of the surveyor.”
1 later decision quote this exact passage · from the majoritye.g. Luker v. Sykes
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.