Coe v. Town of Errol’s Empirical Analysis

Citation profile

140 federal appellate · 93 district · 391 state decisions

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 1,006 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““. . . [N]o definite rule has been adopted with regard to the point of time at which the taxing power of the State ceases as to goods exported to a foreign country or to another State. What we have already said, however, in relation to the products of a State intended for exportation to another State, will indicate the view which seems to us as the sound one on that subject, namely: that such goods do not cease to be part of the general mass of property in the State, subject, as such, to its jurisdiction and to taxation in the usual way, until they have been shipped or entered with a common carrier for transportation to another State or have been started upon such transportation in a continuous route or journey. ’ ’”

   23 later decisions quote this exact passage
   e.g. Kidd v. Pearson · Lehigh Valley Railroad v. Pennsylvania

2. ““It is true, it was said in the case of The Daniel Ball, 10 Wall. 557 , 565, 19 L. Ed. 999 , ‘whenever a commodity has begun to move as an article of trade from one state to another, commerce in that commodity between the states has •commenced.’ But this movement does not begin until the articles have been shipped or started for transportation from the one state to the other. The carrying of them in carts or other vehicles, or even floating them, to the depot where the journey is to commence is no part of that journey. That is all preliminary work, performed for the purpose of putting the property in a state of preparation and readiness for transportation. Until actually launched on its way to another state, or committed to a common carrier for transportation to such state, its destination is not fixed and certain.””

   22 later decisions quote this exact passage
   e.g. State ex rel. Pennsylvania Railroad v. Knight · Kidd v. Pearson

3. ““But granting all this, it may still be pertinently asked: How can property thus situated, to wit, deposited or stored at the place of entrepot for future exportation, be taxed in the regular way as part of the property of the state? The answer is plain. It can be taxed as all other property is taxed, in the place where it is found, if taxed or assessed for taxation, in the usual manner in which such property is taxed; and not singled out to be assessed by itself in an unusual and exceptional manner because of its destination. If thus taxed, in the usual way that other similar property is taxed, and at the same rate, and subject to like conditions and regulations, the tax is valid. In other words, the right to tax' the property being founded on the hypothesis that it is still a part of the general mass of property in the state, it must be treated in all respects as other property of the same kind is treated. “These conditions we understand to have been complied with in the present case. At all events there is no evidence to show that the taxes were not imposed in the regular and ordinary way. As the presumption, so far as mode and manner are concerned, is always in favor of, and not against, official acts, the want of evidence to the contrary must be regarded as evidence in favor of the regularity of the assessment in this case.””

   2 later decisions quote this exact passage
   e.g. United States v. E. C. Knight Co. · Carson Petroleum Co. v. Vial