United States v. Wheeler’s Empirical Analysis
1978
Citation profile
883 federal appellate · 322 district · 459 state decisions
How this case has been cited
Cited by 2,206 later decisions (87 by the Supreme Court) — most recently February 2025 · most notably United States v. Dixon (1993), Santa Clara Pueblo v. Martinez (1978)
883 federal appellate · 322 district · 459 state decisions — followed in 41 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
reviewedUnited States v. Wheeler (from Ninth Circuit Court of Appeals)
Relationships
Relies on Reynolds v. Sims · Brown v. Ohio · Screws v. United States · Bartkus v. People of State of Illinois
Cited together with Santa Clara Pueblo v. Martinez · Montana v. United States · Oliphant v. Suquamish Indian Tribe · Williams v. Lee · Bartkus v. People of State of Illinois
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 2,206 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The sovereignty that the Indian tribes retain is of a unique and limited character. It exists only at the sufferance of Congress and is subject to complete defeasance. But until Congress acts, the tribes retain their existing sovereign powers. In sum, Indian tribes still possess those aspects of sovereignty not withdrawn by treaty or statute, or by implication as a necessary result of their dependent status.”
84 later decisions quote this exact passage · from the majority“"The areas in which such implicit divestiture of sovereignty has been held to have occurred are those involving the relations between an Indian tribe and nonmembers of the tribe .... These limitations rest on the fact that the dependent status of Indian tribes within our territorial jurisdiction is necessarily inconsistent with their freedom independently to determine their external relations . But the powers of self-government, including the power to prescribe and enforce internal criminal laws, are of a different type. They involve only the relations among members of a tribe . Thus, they are not such powers as would necessarily be lost by virtue of a tribe's dependent status."”
34 later decisions quote this exact passage · from the majority“separate people, with the power of regulating their internal and social relations.”
19 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.