Dodge v. Osborn’s Empirical Analysis
240 U.S. 118 · 1916
Citation profile
139 federal appellate · 76 district · 23 state decisions
How this case has been cited
Cited by 409 later decisions (50 by the Supreme Court) — most recently August 2013 · most notably Phillips v. Commissioner (1931), Bob Jones University v. Simon (1974)
139 federal appellate · 76 district · 23 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
reviewedthe decision below (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on State Railroad Tax Cases Taylor Collector et al. v. Secor et al. · Snyder v. Marks · Cheatham v. United States · Shelton v. Platt
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 409 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““No suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court.””
10 later decisions quote this exact passage · from the majority““The remedy so given is exclusive, and no other remedy can be substituted for it. Such has been the current of decisions in the Circuit Courts of the United States, and we are satisfied it is a correct view of the law. [Citations.] In Cheatham v. United States, 92 U. S. 85 , 88 [ 23 L. Ed. 561 ], and again in State Railroad Tax Cases, 92 U. S. 575 , 613 [ 23 L. Ed. 663 ], it was said by this court, that the system prescribed by the United States in regard to both customs duties and internal revenue taxes, of stringent measures, not judicial, to collect them, with appeals to specified tribunals, and suits to recover back moneys illegally exacted was a system of corrective justice intended to be complete, and enacted under the right belonging to the Government to prescribe the conditions on which it would subject itself to the judgment of the courts in the collection of its revenues.””
4 later decisions quote this exact passage · from the majority“* * * if recognized as a basis for equitable jurisdiction, would take every case where a tax was assailed because of its unconstitutionality out of the provisions of the statute, and thus render it nugatory, while it is obvious that the statute plainly forbids the enjoining of a tax unless by some extraordinary and entirely exceptional circumstances its provisions are not applicable.”
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.