Pumpelly v. Green Bay Co.’s Empirical Analysis
80 U.S. 166 · 1871
Citation profile
98 federal appellate · 22 district · 221 state decisions
How this case has been cited
Cited by 623 later decisions (80 by the Supreme Court) — most recently August 2025 · most notably Pennsylvania Coal Co. v. Mahon (1922), Loretto v. Teleprompter Manhattan CATV Corp. (1982)
98 federal appellate · 22 district · 221 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.
Relationships
Relies on Wheeler v. Harris · Scott v. Scott
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 623 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“where real estate is actually invaded by superinduced additions of water, earth, sand, or other material ... so as to effectually destroy or impair its usefulness,”
15 later decisions quote this exact passage · from the majority““It would be a very curious and unsatisfactory result, if in construing a provision or constitutional law, always understood to have been adopted for protection and security to the rights of-the individual as against the government, and which has received the commendation of jurists, statesmen, and commentators as placing the just principles of the common daw on that subject beyond the power of ordinary legislation to change or control them, it shall be held that, if the government refrains from the absolute conversion of real property to the uses of the public, it can destroy its value entirely, can inflict irreparable and permanent injury to any extent, can, in effect, subject it to total destruction without making any compensation, because, in the narrowest sense of that word, it is not taken for the public use. Such a construction would pervert the constitutional provision. into a restriction upon the rights of the citizen, as those rights stood at the common law, instead of the government, and make it an authority for invasion of private right under the pretext of the public good, which had no warrant in the laws or practices of our ancestors.””
9 later decisions quote this exact passage · from the majority““This power to take'private property reaches back of all constitutional provisions; and it seems to have been considered a settled principle of universal law that the right to compensation is an incident to the exercise of that power: that the one is so inseparably connected with the other, that they may be said to exist not as separate and distinct principles, but as parts of one and the same principle. ””
3 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.