Langdeau v. Hanes’s Empirical Analysis
88 U.S. 521 · 1874
Citation profile
8 federal appellate · 2 district · 42 state decisions
How this case has been cited
Cited by 114 later decisions (32 by the Supreme Court) — most recently April 1985 · most notably Wisconsin Cent Co v. Price County (1890), Angle v. Chicago, St. Paul, Minneapolis & Omaha Railway Co. (1894)
8 federal appellate · 2 district · 42 state decisions — followed in 14 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.
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 114 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In the legislation of Congress a patent has a double operation. It is a conveyance by the government when the government has any interest to convey; but, where it is issued upon the confirmation of a claim of a previously existing title, it is documentary evidence, having the dignity of a record, of the existence of that title, or of such equities respecting the claim as justify its recognition and confirmation. The instrument is not the less efficacious as evidence of previously existing rights because it also embodies words of release or transfer from the government.””
8 later decisions quote this exact passage · from the majority““A legislative confirmation of a claim to land is a recognition of the validity of such claim, and operates as effectually as a grant or quitclaim from the government. ‘A confirmation,’ says Sheppard in his Touchstone .of Common Assurances, ‘is the conveyance of an estate, or right, that one hath in or unto lands of tenements, to another that hath the possession thereof, or some estate therein, whereby a voidable estate is made sure and unavoidable, or whereby a particular estate is increased and enlarged.’ If the claim be to land with • defined boundaries, or capable of identification, the legislative confirmation perfects the title to the particular tract, and a subsequent patent is only documentary evidence of that title. If the claim be to quantity, and not to a specific tract capable of identification, a segregation by survey will be required. and the confirmation will then immediately attach the title' to the land segregated.””
4 later decisions quote this exact passage · from the majoritye.g. McNee v. Donahue · Shaw v. Kellogg“1st. That the act. of confirmation of 1807 was a present grant, becoming so far operative and complete, to convey the legal title when the land was located and surveyed by the United States ip 1820, as that an action of ejectment could be maintained on the same.”
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.