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← 65 WVA 39 - Pyle v. Henderson

Pyle v. Henderson’s Empirical Analysis

1909

Citation profile

26
cited by 26 later decisions
4
states following
November 2015
most recently cited

1 federal appellate · 4 district · 19 state decisions

How this case has been cited

Cited by 26 later decisions — most recently November 2015 · most notably Joseph Guffey v. James a Smith (1915), Sahler v. Sahler (1944)

1 federal appellate · 4 district · 19 state decisions

140190919101920193019401950196019701980199020002010decided

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 Williamson v. Jones · Commonwealth ex rel. Attorney General v. Bala & Bryn Mawr Turnpike Co. · Eclipse Oil Co. v. South Penn Oil Co. · Headley v. Hoopengarner · Lowther Oil Co. v. Guffey

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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““One argument made for the second lease is that the first has no covenants' binding the lessees to do anything, unless they wished; that it binds the lessees for nothing, until they should get oil, either to drill a well or pay money; that the lessor could have no suit for money or to compel operation of development of oil. It is thence contended that the contract wants an essential of a binding contract, namely, mutuality. Under this view the lessor could renounce or revoke the lease at any time, because, if not binding the lessee for anything, neither would it bind the lessor, and hence the second lease would be an election by Bunfill not to be bound and would confer good title. * * * We differentiate the present case from the Eclipse Case from the fact that no money was paid as a bbnus in that case, whereas, one of $55 was paid for the lease in this case. We cannot see that when a lessee pays a money consideration for the right or privilege of boring for oil within a fixed time, and in default of so doing, or paying money as alternative, he has no vested right of exploration, but his privilege may be revoked at any moment, whether the limited time has expired or not. If that be tire true view, the clause of cesser is needless, because a revocation could be made for want of mutuality only. It would 'seem to me that a lease of this character, the lessor receiving valuable consideration for the privilege of exploration for oil, would confer a valid right of exploration for th”
    1 later decision 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.