Bates v. Clark’s Empirical Analysis
95 U.S. 204 · 1877
Citation profile
66 federal appellate · 52 district · 44 state decisions
How this case has been cited
Cited by 281 later decisions (48 by the Supreme Court) — most recently March 2026 · most notably Pennhurst State School and Hospital v. Halderman (1984), Butz v. Economou (1978)
66 federal appellate · 52 district · 44 state decisions — followed in 20 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 United States v. Forty-three Gallons of Whiskey · Sundry Goods Wares and Merchandises v. The United States
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 281 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The simple criterion is that as to all the lands thus described it was Indian country whenever the Indian title had not been extinguished, and it continued to be Indian country so long as the Indians had title to it, and no longer. As soon as they parted with the title, it ceased to be Indian country, without any further act of Congress, unless by the treaty by which the Indians parted with their title, or by some act of Congress, a different rule was made applicable to the case.”
10 later decisions quote this exact passage · from the majority““All tluit part of tlie United States west of tlie Mississippi, and not within the states of Missouri and Louisiana, or the territory of Arkansas, and, also, that part of the United States east of the Mississippi river, and not within any state, to which the Indian title shall not have been extinguished, for the purposes of this act be taken and deemed to be the Indian country.””
8 later decisions quote this exact passage · from the majority““Congress . . . and the judges who administered . . . [various other] laws [enacted after 1834], must have found in the definition of Indian country, in the act of 1834, such an adaptability to the altered circumstances of what was then Indian country as to enable them to ascertain what it was at any time since then.” Bates v. Clark, supra, at 207.”
2 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.