United States v. Utah’s Empirical Analysis
283 U.S. 64 · 1931
Citation profile
146 federal appellate · 36 district · 125 state decisions
How this case has been cited
Cited by 476 later decisions (43 by the Supreme Court) — most recently March 2025 · most notably Crowell v. Benson (1932), Kaiser Aetna v. United States (1979)
146 federal appellate · 36 district · 125 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.
Relationships
Relies on Shively v. Bowlby · The Daniel Ball · Donnelly v. United States · United States v. Cress · United States v. Holt State Bank
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 476 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Those rivers must be regarded as public navigable rivers in law which are navigable in fact. And they are navigable in fact when they are used, or are susceptible of being used, in their ordinary condition, as highways for commerce, over which trade and travel are or may be conducted in the customary modes of trade and travel on water.”
17 later decisions quote this exact passage · from the majority“rather than the mere manner or extent of actual use....”
5 later decisions quote this exact passage · from the majority“It is true that the region through which the rivers flow is sparsely settled.... In view of past conditions, the government urges that the consideration of future commerce is too speculative to be entertained. Rather it is true that, as the title of a state depends upon the issue, the possibilities of growth and future profitable use are not to be ignored. Utah, with its equality of right as a state of the Union, is not to be denied title to the beds of such of its rivers as were navigable in fact at the time of the admission of the state either because the location of the rivers and the circumstances of the exploration and settlement of the country through which they flowed had made recourse to navigation a late adventure or because commercial utilization on a large scale awaits future demands. The question remains one of fact as to the capacity of the rivers in their ordinary condition to meet the needs of commerce as these may arise in connection with the growth of the population, the multiplication of activities, and the development of natural resources. And this capacity may be shown by physical characteristics and experimentation as well as by the uses to which the streams have been put.”
4 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.