Case Citator › Chicot County Drainage District v. Baxter State Bank

Chicot County Drainage District v. Baxter State Bank

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
308 U.S. 371
Decided
Confirmed treatments
2
Flagged citations read
60 of 60
Citing cases (total)
60
Treatment dates
1940–1972
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Chicot County Drainage District v. Baxter State Bank has been limited: all 60 flagged citations have been examined, and the two confirmed limits are listed below. The Supreme Court held that Chicot does not govern the waiver of sovereign immunity.
More on how this was screened

The Second Circuit later declined to extend its civil judgment rule to criminal litigation. Other citing opinions applied Chicot, quoted it in discussions of retroactivity, or described its treatment of an earlier decision. The published text of Paramount Film Distributing Corp. v. State (1971) contains no Chicot citation despite its index match; no treatment was inferred from that opinion. The Frakes v. Hunt dissent, omitted from the ordinary text, was read from its published opinion and cites Chicot approvingly.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

60 later cases cite Chicot County Drainage District v. Baxter State Bank; 60 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Chicot County Drainage District v. Baxter State Bank?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Supreme Court held that Chicot's rule against collateral attacks does not apply when the earlier judgment exceeded a sovereign's consent to suit.

    United States v. United States Fidelity & Guaranty Co. · Supreme Court of the United States · filed

    In the Chicot County case no inflexible rule as to collateral objection in general to judgments was declared. We explicitly limited our examination to the effect of a subsequent invalidation of the applicable' jurisdictional statute upon an existing judgment in bankruptcy.
    Read the full opinion on CourtListener →

  • The Second Circuit declined to extend Chicot's civil judgment rule to a criminal challenge involving liberty and fair trial rights.

    United States ex rel. Flemings v. Chafee · Second Circuit · filed

    Chicot, however, was not a criminal case, nor was it concerned with the liberty or the fundamental rights to a fair trial. ... The recent decision in United States v. United States Coin & Currency, supra, buttresses our conclusion that Chicot should not be transported ipse dixit to the arena of criminal litigation.
    Read the full opinion on CourtListener →

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