Federal Power Commission v. Niagara Mohawk Power Corp.’s Empirical Analysis
1954
Citation profile
109 federal appellate · 6 district · 37 state decisions
How this case has been cited
Cited by 261 later decisions (25 by the Supreme Court) — most recently May 2022 · most notably United States v. Virginia Electric & Power Co. (1961), United States v. Twin City Power Co. (1956)
109 federal appellate · 6 district · 37 state decisions — followed in 13 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
reviewedHart v. Williams (from District of Columbia Circuit Court of Appeals)
Relationships
Applies 16 U.S.C. § 791A (§ 321 of the Federal Power Act of 1920) · 16 U.S.C. § 796 (§ 3 of the Federal Power Act of 1920) · 16 U.S.C. § 803 (§ 10 of the Federal Power Act of 1920) · 16 U.S.C. § 807 (§ 14 of the Federal Power Act of 1920) · 16 U.S.C. § 809 (§ 16 of the Federal Power Act of 1920) · 16 U.S.C. § 813 (§ 20 of the Federal Power Act of 1920) · 16 U.S.C. § 816 (§ 23 of the Federal Power Act of 1920) · 16 U.S.C. § 820 (§ 26 of the Federal Power Act of 1920)
Relies on United States v. Appalachian Electric Power Co. · United States v. Chandler-Dunbar Water Power Co. · United States v. Cress · First Iowa Hydro-Electric Cooperative v. Federal Power Commission · United States v. Gerlach Live Stock Co.
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 261 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The Act treats usufructuary water rights like other property rights. While leaving the way open for the exercise of the federal servitude and of federal rights of purchase or condemnation, there is no purpose expressed to seize, abolish or eliminate water rights without compensation merely by force of the Act itself.”
2 later decisions quote this exact passage · from the majority“has complied with the requirements of the laws of the State or States within which the proposed project is to be located with respect to bed and banks and to the appropriation, diversion, and use of water for power purposes and with respect to the right to engage in the business of developing, transmitting, and distributing power, and in any other business necessary to effect the purposes of a license under this chapter.”
1 later decision quote this exact passage · from the majoritye.g. Paul v. Jackson““ * * * We find nothing in the Federal Water Power Act justifying such an interpretation. Neither it, nor the license issued under it, expressly abolishes any existing pro prietary rights to use waters of the Niagara River. * * * On the contrary, the plan of the Act is one of reasonable regulation of the use of navigable waters, coupled with encouragement of their development as power projects by private parties.””
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.