United States v. Holt State Bank’s Empirical Analysis
270 U.S. 49 · 1926
Citation profile
185 federal appellate · 58 district · 148 state decisions
How this case has been cited
Cited by 604 later decisions (74 by the Supreme Court) — most recently March 2025 · most notably Crowell v. Benson (1932), Idaho v. Coeur Tribe of Idaho (1997)
185 federal appellate · 58 district · 148 state decisions — followed in 25 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
reviewedHarrison v. Fite (from Eighth Circuit Court of Appeals)
Relationships
Relies on Shively v. Bowlby · The Daniel Ball · United States v. Cress · United States v. Lineas Winans · State of Minnesota v. Ethan Allen Hitchcock
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 604 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is settled law in this country that lands underlying navigable waters within a state belong to the State in its sovereign capacity....”
20 later decisions quote this exact passage · from the majority“[Njavigability does not depend on the particular mode in which such use is or may be had — whether by steamboats, sailing vessels or flatboats — nor on an absence of occasional difficulties in navigation, but on the fact, if it be fact, that the stream in its natural and ordinary condition affords a channel for useful commerce.”
13 later decisions quote this exact passage · from the majority“there was nothing in [the treaties] which even approaches a grant of rights in lands underlying navigable waters.”
8 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.