Friedman v. Texaco, Inc.’s Empirical Analysis
1985
Citation profile
11 state decisions
How this case has been cited
Cited by 12 later decisions — most recently March 2014
11 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.
Appellate journey
reviewedthe decision below (from Texas Court of Appeals, 4th District (San Antonio))
Relationships
Relies on Heinatz v. Allen · Acker v. Guinn · Moser v. United States Steel Corp. · Reed v. Wylie · Cain v. Neumann
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[tjhat with respect to uranium, the rules of Acker and Reed will apply to determine the effect of severances of ‘other minerals’ from the surface estate for severances prior to June 8, 1983. These rules will apply even in cases where there has been no reliance on Acker and Reed because the minerals conveyed in a pre-Acker severance should not depend on the fortuitous event of reliance on subsequent law by a subsequent lessee or purchaser. For severances of ‘other minerals’ from the surface after June 8, 1983, title to uranium will be determined by the rules announced in Moser . If mineral and surface estates severed prior to June 8, 1983 have merged, and are subsequently reserved after June 8, 1983, the rules announced in Moser will apply thereafter.”
1 later decision quote this exact passage“In neither the Acker opinion nor the Reed opinions did we state that the holdings were to be prospective in application. Furthermore, we did not purport to change the law in Acker , and our opinions in the Reed cases were extensions of the rule set out in Acker . The surface destruction test was not a new concept. As early as 1949 this court held that surface destruction was a factor in determining whether a substance was included in a conveyance or reservation of ‘minerals.’ Heinatz v. Allen, 147 Tex. 512 , 217 S.W.2d 994, 998 (1949)....”
1 later decision quote this exact passage“The court held: We now hold a severance of minerals in an oil, gas and other minerals clause includes all substances within the ordinary and natural meaning of that word, whether their presence or value is known at the time of severance.... We also hold uranium is a mineral within the ordinary and natural meaning of the word. [[Image here]] [t]he rules announced in this case are to be applied only prospectively from the date of our original opinion, June 8,1983.”
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.