Bowen v. Johnston’s Empirical Analysis
306 U.S. 19 · 1939
Citation profile
433 federal appellate · 97 district · 169 state decisions
How this case has been cited
Cited by 1,063 later decisions (82 by the Supreme Court) — most recently January 2025 · most notably Fay v. Noia (1963), Preiser v. Rodriguez (1973)
433 federal appellate · 97 district · 169 state decisions — followed in 27 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
reviewedBowen v. Johnson (from Ninth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 41
Relies on Johnson v. Zerbst · Ex parte Lange · Ex Parte Nielsen · Moore v. Dempsey · James v. Dravo Contracting Co.
Cited together with Fay v. Noia · Johnson v. Zerbst · Hill v. United States · Darr v. Burford · Royall
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 1,063 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The rule of exhaustion 'is not one defining power but one which relates to the appropriate exercise of power.'”
30 later decisions quote this exact passage · from the majority“exceptional circumstances where the need for the remedy afforded by the writ of habeas corpus is apparent.”
13 later decisions quote this exact passage · from the majority“[t]o exercise exclusive legislation in all cases whatsoever, . . . over all places purchased by the consent of the legislature of the state in which the same shall be, for the erection of forts, magazines, arsenals, dock-yards and other needful buildings ....”
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.