Nichols v. Rysavy’s Empirical Analysis
809 F.2d 1317 · 1987
Citation profile
16 federal appellate · 6 district · 2 state decisions
How this case has been cited
Cited by 33 later decisions — most recently December 2020 · most notably Hopkins v. Saunders (1999), Lee v. United States (1987)
16 federal appellate · 6 district · 2 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
Applies 25 U.S.C. § 331 (White Earth Reservation Land Settlement Act of 1985) · 25 U.S.C. § 345 · 25 U.S.C. § 347 · 25 U.S.C. § 349 · 25 U.S.C. § 352A · 25 U.S.C. § 352B · 25 U.S.C. § 461 · 25 U.S.C. § 483
Relies on Wilson v. Garcia · Consumer Product Safety Commission v. GTE Sylvania, Inc. · Quern v. Jordan · Affiliated Ute Citizens of Utah v. United States · Morton v. Mancari
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Rule 19(b) suggests four ‘interests’ that must be examined in each case to determine whether, in equity and good conscience, the court should proceed without a party whose absence from the litigation is compelled.... First, the plaintiff has an interest in having a forum.... Second, the defendant may properly wish to avoid multiple litigation, or inconsistent relief, or sole responsibility for a liability he shares with another.... Third, there is the interest of the outsider whom it would have been desirable to join.... Fourth, there remains the interest of the courts and the public in complete, consistent, and efficient settlement of controversies.””
3 later decisions quote this exact passage · from the majority““In examining these two factors, we note that if appellants prevailed in this suit, the United States would be reinstated as trustee over the land, with the concomitant resumption of fiduciary responsibility, and could also be subject to claims for damages by the present owners. Furthermore, the result of this suit, on the merits, would depend entirely on whether the United States acted legally or illegally in granting fee patents under the blood quantum policy. If the United States issued the patents legally, then appellants’ action is groundless. ‘In short the government’s liability cannot be tried “behind its back” ’ (citation omitted).””
2 later decisions quote this exact passage · from the majority“If a person as described in subdivision (a)(l-2) hereof cannot be made a party, the court shall determine whether in equity and good conscience the action should proceed among the parties before it, or should be dismissed, the absent person thus being regarded as indispensable. The factors ... include: first, to what extent a judgment rendered in the person’s absence might be prejudicial to the person or those already parties; second, the extent to which, by protective provision in the judgment, by the shaping of relief, or other measures, the prejudice can be lessened or avoided; third, whether a judgment rendered in the person’s absence will be adequate; fourth, whether the plaintiff will have an adequate remedy if the action is dismissed for nonjoinder.”
1 later decision 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.