Factor v. Laubenheimer’s Empirical Analysis
290 U.S. 276 · 1933
Citation profile
257 federal appellate · 51 district · 20 state decisions
How this case has been cited
Cited by 596 later decisions (25 by the Supreme Court) — most recently June 2025 · most notably Volkswagenwerk Aktiengesellschaft v. Schlunk (1988), United States v. Alvarez-Machain (1992)
257 federal appellate · 51 district · 20 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
reviewedLaubenheimer v. Factor (from Seventh Circuit Court of Appeals)
Relationships
Relies on Terrace v. Thompson · Collins v. Loisel · United States v. Rauscher · Springer v. Government of the Philippine Islands Agoncillo · Charlton v. Kelly
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 596 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[i]n choosing between conflicting interpretations of a treaty obligation, a narrow and restricted construction is to be avoided as not consonant with the principles deemed controlling in the interpretation of international agreements. Considerations which should govern the diplomatic relations between nations, and the good faith of treaties, as well, require that their obligations should be liberally construed so as to effect the apparent intention of the parties to secure equality and reciprocity between them. For that reason, if a treaty fairly admits of two constructions, one restricting the rights which may be claimed under it, and the other enlarging it, the more liberal construction is to be preferred.”
11 later decisions quote this exact passage · from the majority“more liberally than a criminal statute or the technical requirements of criminal procedure.”
8 later decisions quote this exact passage · from the majority“And in resolving doubts the construction of a treaty by the political department of the government, while not conclusive upon courts called upon to construe it, is nevertheless of weight.”
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.