Steelsmith v. Gartlan’s Empirical Analysis
1898
Citation profile
6 federal appellate · 47 state decisions
How this case has been cited
Cited by 57 later decisions — most recently June 2008 · most notably Joseph Guffey v. James a Smith (1915), Rich v. Doneghey (1918)
6 federal appellate · 47 state decisions — followed in 14 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.
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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A vested title cannot ordinarily be lost by abandonment in a less time than fixed by the statute of limitations, unless there is satisfactory proof of an intention to abandon. An oil lease stands on quite a different ground. The title is inchoate, and for the purpose of exploration only until oil is found. If it is not found, no estate vests in the lessee, and his title, whatever it is, ends whenever the unsuccessful search is abandoned.””
1 later decision quote this exact passagee.g. Huggins v. Daley“Then why should she [lessor] pay for it by a nonoperating and indefinite extension of the lease, to await the will and pleasure of the lessee, who claims the option to operate, abandon, surrender, or forfeit at his pleasure, while numerous others are clamoring for the privilege of diligent operation, and offering a large bonus therefor? Such a holding would be unconscionable, and contrary to both right and justice.”
1 later decision quote this exact passage“■ “He could not be compelled to put down another well, and, he not being bound, the lessor was not bound, either; for the only consideration left to him was the prospective oil royalties and gas rentals, which the lessee was in position to'entirely defeat. Contracts unperformed, optional as to one of the parties, are optional as to both.””
1 later decision quote this exact passagee.g. Huggins v. Daley
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.