Spreckels Sugar Refining Company v. Penrose a McClain’s Empirical Analysis
192 U.S. 397 · 1904
Citation profile
77 federal appellate · 22 district · 14 state decisions
How this case has been cited
Cited by 214 later decisions (47 by the Supreme Court) — most recently July 2007 · most notably Flint v. Stone Tracy Co. (1911), Brushaber v. Union Pacific Railroad (1916)
77 federal appellate · 22 district · 14 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Appellate journey
reviewedSpreckels Sugar Refining Co. v. McClain (from Third Circuit Court of Appeals)
Relationships
Relies on Yick Wo v. Hopkins · Knowlton v. Moore · Pollock v. Farmers' Loan & Trust Co. · Pollock v. Farmers' Loan & Trust Co. · James Patton v. Maggie a Brady J D
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 214 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““But the ease distinctly presented other questions which involved simply the construction of the act, and those questions were disposed of by the Circuit Court at the same time it determined the question of the constitutionality of the act. If the case had depended entirely on the construction of the act of Congress — its constitutionality not being drawn in question — it would not have been one of those described in the fifth section of the act of 1891, and, consequently, could not have come here directly from the Circuit Court. As, then, the case, made by the plaintiff, involved a question other than those relating to the constitutionality of the act and to the application and construction of the Constitution, the Circuit Court of Appeals had jurisdiction to review the judgment, of the Circuit Court, although if the plaintiff had elected to bring it here directly, this court would have had jurisdiction to determine all the questions arising upon the record. The plaintiff was entitled to bring it here directly from the Circuit Court, or, at its election, to go to the Circuit Court of Appeals for a review of the whole case.””
3 later decisions quote this exact passage · from the majority““Sec. 27. That every person, firm, corporation, or company carrying on or doing the business of refining petroleum, or refining sugar, or owning or controlling any pipe line for transporting oil or other products, whose gross annual receipts ex ceed two hundred and fifty thousand dollars, shall be subject to pay annually a special excise tax equivalent to one-quarter of one per centum on the gross amount of all receipts of such persons, firms, corporations, and companies in their respective business in excess of said sum of two hundred and fifty thousand dollars.””
2 later decisions quote this exact passage · from the majority““Keeping in mind the well-settled rule that the citizen is exempt from taxation, unless the same is imposed by clear and unequivocal language, and that, where the construction of a tax is doubtful, the doubt is to be resolved in favor .of those upon whom the tax is sought to be laid.””
2 later decisions quote this exact passage · from the dissent
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.