Kinney-Coastal Oil Co. v. Kieffer’s Empirical Analysis
277 U.S. 488 · 1928
Citation profile
38 federal appellate · 21 district · 32 state decisions
How this case has been cited
Cited by 108 later decisions (2 by the Supreme Court) — most recently June 2025 · most notably United States v. Gould (2004), Reno Livestock Corp. v. Sun Oil Co.(Delaware) (1981)
38 federal appellate · 21 district · 32 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.
Appellate journey
reviewedthe decision below (from Eighth Circuit Court of Appeals)
Relationships
Relies on The Harrisburg · Kohl v. United States · McGowan v. Parish · Singer Sewing Machine Co. v. Benedict · Joseph Parker Camp v. Kate Willard Boyd
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 108 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The acts of 1914 and 1920 are to be read together-each as the complement of the other. So read they disclose an intention to divide oil and gas lands into two estates for the purposes of disposal-one including the underlying oil and gas deposits and the other the surface-and to make the latter servient to the former, which naturally would be suggested by their physical relation and relative values. . . . . In effect therefore a servitude is laid on the surface estate for the benefit of the mineral estate to the end, as the acts otherwise show, that the United States may realize, through the separate leasing, a proper return from the extraction and removal of the minerals.”
3 later decisions quote this exact passage · from the majority““So, while the provision on which the decision of the Circuit Court of Appeals rests cannot be held to be an obstacle to the maintenance of this suit in a court of equity, we think it shows a need for modifying the decree of the District Court by providing therein for an ascertainment in this suit of any damages which the plaintffs’ entry and operations under the lease may have caused to the agricultural improvements or crops of the owner of the surface estates . . . . ” (Italics supplied.)”
1 later decision quote this exact passage · from the majority““The only compensation which he rightfully may demand is, as the act of 1914 says, for ‘damages caused’ by the mining operations. The sentence next preceding that in which these words occur makes it fairly plain that they refer to damages to ‘crops and improvements,’ and the title to the act, coupled with the reference to ‘crops’ shows that ‘agricultural’ improvements are the kind intended.””
1 later decision 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.