Brown v. Havard’s Empirical Analysis
1980
Citation profile
32 state decisions
How this case has been cited
Cited by 34 later decisions — most recently June 2018 · most notably Cherokee Water Co. v. Forderhause (1987), French v. Chevron U.S.A. Inc. (1995)
32 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.
Relationships
Relies on Western Union Telegraph Co. v. Texas Employment Commission · Universal C. I. T. Credit Corp. v. Daniel · Woods v. Sims · Miles v. Martin · Morrow v. Shotwell
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[1] The Grantors herein reserve unto themselves, their heirs and assigns, and except from this conveyance an undivided one-half (1/2) Royalty (Being equal to not less than an undivided one-six-teent[h] (1/16)[) ] of all the oil, gas and/or other minerals in, to, and under or that may be produced from said ... land aforesaid, to be paid or delivered to said Grantors, as their own property, free of cost Forever; together with the right of ingress and egress at all times for the purpose of storing, treating, marketing and removing the same therefrom. [2] Said interest hereby reserved is a Non-Participating Royalty and shall not participate in the Bonuses paid for any oil, gas or other minerals] lease covering said land, nor shall it participate in the money rentals which may be paid to extend the time within which a well may be begun under the terms of any lease covering said land. It shall not be necessary for the Grantors, their heirs, and assigns, to join in the execution of any lease covering said Royalty interest herein reserved, and the Grantee herein, his heirs and assigns, shall have the right to lease said land for oil, gas and other minerals provided, however, that all such leases shall provide for Royalty of not less than one-eighth (1/8): (a) on oil, gas and other minerals, liquid or solid; (b) Of the net proceeds from the sale of liquid hydrocarbons such as gasoline, butane, propane or from the sale of any other manufactured or processed by-products extracted or rec”
3 later decisions quote this exact passage“The mistake at issue in Brown arose out of an ambiguous reservation of a royalty interest contained in the deed from Brown to Havard’s immediate predecessor in title. The Brown court fairly summed up the rule enunciated by the above-cited authorities to be, that while the four-year statute of limitations ... is applicable to suits seeking reformation of instruments, the statute does not begin to run until the mistake is, or in the exercise of reasonable diligence, should have been discovered. Such is unquestionably the rule in Texas.”
2 later decisions quote this exact passage
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.