State v. Forge’s Empirical Analysis
1977
Citation profile
6 federal appellate · 8 state decisions
How this case has been cited
Cited by 15 later decisions (1 by the Supreme Court) — most recently February 2012
6 federal appellate · 8 state decisions
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
Applies 18 U.S.C. § 1151 (Indian Crimes Act of 1976) · 18 U.S.C. § 1162 · 25 U.S.C. § 461 · 25 U.S.C. § 891 · 28 U.S.C. § 1360
Relies on Morton v. Mancari · McClanahan v. State Tax Commission of Arizona · Bryan v. Itasca County · United States v. Lineas Winans · Kugler v. Helfant
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 15 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Although the disestablishment effect of the Nelson Act is not free from doubt, we are convinced after a review of the voluminous authorities cited to us that the act did not terminate the Leech Lake Reservation. * * * * * * "* * * to the extent the Nelson Act is unclear in expressing congressional intent to terminate the Leech Lake Reservation, this ambiguity should not be resolved to the prejudice of the Indians. As has been repeatedly recognized by the United States Supreme Court, `statutes passed for the benefit of dependent Indian tribes or communities are to be liberally construed, doubtful expressions being resolved in favor of the Indians.' Alaska Pacific Fisheries v. United States, 248 U.S. 78, 89 , 39 S.Ct. 40, 42 , 63 L.Ed. 138, 141 (1918). Accord, Bryan v. Itasca County, Minnesota, 426 U.S. 373 , 96 S.Ct. 2102 , 48 L.Ed.2d 710 (1976); Antoine v. Washington, 420 U.S. 194 , 95 S.Ct. 944 , 43 L.Ed.2d 129 (1975). This canon of construction is reflective of the fact that treaties and statutes are `not a grant of rights to the Indians, but a grant of rights from them a reservation of those not granted.' United States v. Winans, 198 U.S. 371, 381 , 25 S.Ct. 662, 664 , 49 L.Ed. 1089, 1092 (1905). Had Congress intended to terminate completely the Leech Lake Reservation and the right of the Chippewa to fish thereon, we believe that it could have, and would have, expressed this intention with more definiteness and, in all likelihood, would not have permitted the Band, by §”
2 later decisions quote this exact passage“for the complete cession and relinquishment in writing of all their title and interest in and to all the reservations of said Indians in the State of Minnesota, except the White Earth and Red Lake[ [11] ] Reservations * * *.”
1 later decision quote this exact passagee.g. State v. Clark“Although the disestablishment effect of the Nelson Act is not free from doubt, we are convinced after a review of the voluminous authorities cited to us that the act did not terminate the Leech Lake Reservation. * * * * * *”
1 later decision quote this exact passagee.g. State v. Clark
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.