Atchison Topeka Santa Fe Railway Company v. Timothy O'Connor’s Empirical Analysis
223 U.S. 280 · 1912
Citation profile
69 federal appellate · 45 district · 142 state decisions
How this case has been cited
Cited by 393 later decisions (64 by the Supreme Court) — most recently May 2016 · most notably Pennhurst State School and Hospital v. Halderman (1984), Butz v. Economou (1978)
69 federal appellate · 45 district · 142 state decisions — followed in 31 states
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.
Relationships
Relies on Ex Parte: Edward T Young · Poindexter v. Greenhow · Union Refrigerator Transit Company v. Commonwealth of Kentucky · Galveston Harrisburg San Antonio Railway Company v. State of Texas · Henderson v. Mayor of the City of New York Commissioners of Immigration v. North German Lloyd
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 393 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“it is reasonable that a man who denies the legality of a tax should have a clear and certain remedy. The rule being established that, apart from special circumstances, he cannot interfere ... with the State's collection of its revenues, an action at law to recover back what he has paid is the alternative left.”
8 later decisions quote this exact passage · from the majority“In this case the law, beside giving an action of debt to the State, provides that every corporation that fails to pay the tax shall forfeit its right to do business within the State until the tax is paid, and also shall pay a penalty of ten per cent.... It may be that the forfeiture of the right to do business would not be authoritatively established except by a quo warranto ..., but before or without the proceeding the effect of the forfeiture clause upon the plaintiff’s subsequent contracts and business might be serious ..., and in any event the penalty would go on accruing. ... As appears from the decision below, the plaintiff could have had no certainty of ultimate success, and we are of opinion that it was not called upon to take the risk of having its contracts disputed and its business injured and of finding the tax more or less nearly doubled in case it finally had to pay. In other words, we are of opinion that the payment was made under duress.”
2 later decisions quote this exact passage · from the majority“if it shall be determined in any action at law or in equity that any corporation has erroneously paid said tax to the Secretary of State,”
1 later decision quote this exact passage · from the majoritye.g. Jagnandan v. Giles
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.