Note 539 — ARTICLE III (continued 2)

The Tyson doctrine was extended to wills in Lane v. Vick, 3 How. 464 (1845); to torts in Chicago City v. Robbins, 2 Bl. 418 (1862); to real estate titles and the rights of riparian owners in Yates v. Milwaukee, 10 Wall. 497 (1870); to mineral conveyances in Kuhn v. Fairmont Coal Co., 215 U.S. 349 (1910); to contracts in Rowan v. Runnels, 5 How. 134 (1847); and to the right to exemplary or punitive damages in Lake Shore & M.S.R. Co. v. Prentice, 147 U.S. 101 (1893). By 1888 there were 28 kinds of cases in which federal and State courts applied different rules of the common law. See George C. Holt, The Concurrent Jurisdiction of the Federal and State Courts (New York, 1888), 159-188.