China 9, Liberty 37 falls halfway between the Hollywood backlot-western school and the Italian "spaghetti" western genre, borrowing the best elements from both. Fabio Testi plays a gunfighter who is saved at the last moment from a hangman's noose. His liberators are a cartel of railroad men who want Testi to kill farmer (and former hired gun) Warren Oates, who has refused all entreaties to sell his land. As part of the scheme, Testi befriends Oates; on his own volition, he sleeps with Oates' wife Jenny Agutter. When the railroad barons insist that Testi go through with his mission, he refuses, and helps the farmer fight off the train moguls' hired thugs. Also known as Gunfire, China 9 Liberty 37 features a cameo by director Monte Hellman's role model, Sam Peckinpah, who plays a bombastic Ned Buntline-style novelist. And the significance of the title? It's the location of Warren Oates' spread: Nine miles from the town of China, 37 miles from the town of Liberty.
~ Hal Erickson, All Movie Guide