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← 232 Ark. 57 - Wayland v. Snapp

Wayland v. Snapp’s Empirical Analysis

1960

Citation profile

39
cited by 39 later decisions
10
states following
June 2011
most recently cited

37 state decisions

How this case has been cited

Cited by 39 later decisions — most recently June 2011 · most notably City of Little Rock v. Raines (1967), Green v. City of Mt. Pleasant (1964)

37 state decisions — followed in 10 states

130196019701980199020002010decided

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 Chas Steward Mach Co v. Davis · Albritton v. City of Winona · Newberry v. City of Andalusia · Opinion of the Justices · Hogue v. the Housing Auth. of North Little Rock

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

  1. “In his Complaint appellant alleges that: “The City of Batesville has represented to Seiberling that the land and manufacturing facilities to be leased to Seiberling by the City will be exempt from ad valorem taxes” in violation of Article 16, Sections 5 and 6 of the Arkansas Constitution. * * * As we understand the above provisions of the Constitution, for property to be exempted from taxation two elements must be present: (a) the subject property must be “public property,” that is, it must be owned (in this instance) by the City of Batesville; (b) it must be used exclusively for public purposes. In our opinion both of these elements, are present in the case under consideration as we shall attempt to show. (a) It must be admitted here that the grounds, the building and facilities will be owned by the City of Batesville and will, therefore, be public property. (b) Likewise, we think it is clear that the property will be used exclusively for a public purpose. If it is, it will be exempt from taxation under the Constitution and if it is not it must be taxed.”
    1 later decision quote this exact passage
  2. “As we understand the above provisions of the Constitution, for property to be exempted from taxation two elements must be present: (a) the subject property must be “public property”, that is, it must be owned [in this instance] by the City of Batesville; (b) it must be used exclusively for public purposes. In our opinion both of these elements are present .... Any benefit [the manufacturer] may receive from this entire undertaking will be entirely incidental it seems to us.”
    1 later decision quote this exact passage
  3. “The constitution exempts “public property used exclusively for public purposes.” Const., Art. 16 § 5. Obviously the framers did not mean to exempt all public property, for in that event there would have been no need to insert the phrase, “used exclusively for public purposes.” The inclusion of that phrase demonstrates conclusively that the exemption does not embrace all publicly owned property; it must also be used exclusively for a public purpose.”
    1 later decision quote this exact passage

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.