Meriwether v. Lovett’s Empirical Analysis

Citation profile

22 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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““From the expressions above quoted from the Supreme Court of the United States and from the prior decisions of this court, it appears certain that the Legislature has seen fit to classify mineral rights in lands from which oil and gas are being produced as a distinct classification of property for taxation, not upon an ad valorem basis, but upon the basis of production as a substitute for ad valorem taxes. No complaint is here urged as to the justice of said tax, for such tax has been paid. The Legislature recognized the difficulty of taxing on an ad valorem basis the mineral contents of land, by reason of lack of definite knowledge of the extent thereof and of the labor and expense of gaining actual dominion over the same. It recognized, however, that tremendous values were contained in hidden natural resources, deep in the earth, and. that an active industry was extracting said natural resources and that same should bear its just part of the expenses of government. It therefore saw fit to classify mineral rights in lands, from which production of said minerals was being had, as a classification of property on which the state should exact a tax.”

   2 later decisions quote this exact passage
   e.g. Peteet v. Carmichael · Caney Production Co. v. Kane

2. “"Every person, firm, association or corporation engaged in the mining or production, within this State * * * of petroleum or other crude oil or other mineral oil, natural gas and/or casinghead gas, shall, monthly, file with the Oklahoma Tax Commission, a statement under oath, on forms prescribed by it, showing the location of each mine or oil or gas well operated or controlled by such person, firm, corporation or association during the last preceding monthly period; the kind of such mineral, oil or gas produced; the gross amount thereof produced; and the actual cash value thereof at the time and place of production, including any and all premiums received from the sale thereof; * * *, and shall, at the same time pay * * * a tax equal to five per centum of the gross value of the production of petroleum or other crude or mineral oil which is hereby levied * * *."”

   1 later decision quote this exact passage
   e.g. Atlantic Refining Co. v. Oklahoma Tax Commission

3. ““The issue presented here is whether the unproduced minerals in the strata of the earth, previously conveyed, and the working interest under the oil and gas leases are subject to the ad valorem taxes assessed against the land itself, separately owned, during a time when oil and gas were being produced from said land and the gross production taxes were being paid on the oil so produced. ⅝ ⅝ ⅝ ⅜ * ⅝ “It is to be noted that the determination of the essential question does not involve a consideration of the non-payment of ad valorem taxes on lands where no production of oil and gas is being had, and consequently no gross production taxes are being paid.””

   1 later decision quote this exact passage
   e.g. Caney Production Co. v. Kane