United States of America v. Lexington Mill & Elevator Company’s Empirical Analysis
232 U.S. 399 · 1914
Citation profile
142 federal appellate · 27 district · 31 state decisions
How this case has been cited
Cited by 319 later decisions (29 by the Supreme Court) — most recently August 2008 · most notably Caminetti v. United States (1917), Federal Trade Commission v. Morton Salt Co. (1948)
142 federal appellate · 27 district · 31 state decisions — followed in 10 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.
Appellate journey
reviewedLexington Mill & Elevator Co. v. United States (from Eighth Circuit Court of Appeals)
Relationships
Relies on Gibbons v. Ogden · Rector Etc of Holy Trinity Church v. United States · Mugler v. State of Kansas State of Kansas Tufts · Joseph Lochner v. People of the State of New York · Lawton v. Steele
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 319 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If a legislative purpose is expressed in 'plain and unambiguous language, ... the ... duty of the courts is to give it effect according to its terms'”
5 later decisions quote this exact passage · from the majority“‘‘It is not required that the article of food containing added poisonous or other added deleterious ingredients must affect the public health, and it is not incumbent upon the Government in order to make out a case to establish that fact. The act has placed upon the Government the burden of establishing, in order to secure a verdict of condemnation under this statute, that the added poisonous or deleterious substances must be such as may render such article injurious to health. The word ‘may’ is here used in its ordinary and usual signification, there being nothing to show the intention of Congress to affix to it any other meaning. ... In thus describing the offense Congress doubtless took into consideration that flour may be used in many ways, in bread, cake, gravy, broth, etc. It may be consumed, when prepared as a food, by the strong and the weak, the old and the young, the well and the sick; and it is intended that if any flour, because of any added poisonous or other deleterious ingredient, may possibly injure the health of any of these, it shall come within the ban of the statute. If it cannot by any possibility, when the facts are reasonably considered, injure the health of any consumer, such flour, though having a small addition of poisonous or deleterious ingredients, may not be condemned under the act. This is the plain meaning of the words and in our view needs no additional support....” (Emphasis supplied.)”
4 later decisions quote this exact passage · from the majority““The statute upon its face shows that the primary purpose of Congress was to prevent injury to the public health by the sale and transportation in interstate commerce of mis-branded and adulterated foods. The legislation, as against misbranding, intended to make it possible that the consumer should know that an article purchased was what it purported to be; that it might be bought for what it really was and not upon misrepresentations as to character and quality. As against adulteration, the statute was intended to protect the public health from possible injury by adding to articles of food consumption poisonous and deleterious substances which might render such articles injurious to the health of consumers.””
3 later decisions quote this exact passage · from the majority
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.