Pullman Co. v. Richardson’s Empirical Analysis
261 U.S. 330 · 1923
Citation profile
8 federal appellate · 8 district · 60 state decisions
How this case has been cited
Cited by 154 later decisions (45 by the Supreme Court) — most recently November 2003 · most notably James v. Dravo Contracting Co. (1937), Minneapolis Star and Tribune Company v. Minnesota Commissioner of Revenue (1983)
8 federal appellate · 8 district · 60 state decisions — followed in 15 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 Gloucester Ferry Co v. Commonwealth of Pennsylvania · Galveston Harrisburg San Antonio Railway Company v. State of Texas · Leloup v. Port of Mobile · Western Union Telegraph Co. v. Kansas ex rel. Coleman · St. Louis Southwestern Railway Co. v. Arkansas
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 154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A state can neither tax the act of engaging in interstate commerce nor lay a tax on gross receipts therefrom. In either case the tax would be a restraint or burden on such commerce and its imposition and invasion of the power of regulation confided to Congress by the commerce clause of the Constitution. * * * “The rule is otherwise with property used in interstate commerce. A state within whose limits such property is permanently located or commonly used may tax it. * * * And, if the property be part of a system and have an augmented value by reason of a connected operation of the whole, it may be taxed according to its value as part of the system, although the other parts be outside the state; in other words, the tax may be made to cover the enhanced value which comes to the property in the state through its organic relation to the system. * * * “In taxing property so situated and used, a state may select and employ any appropriate means of reaching its actual or full value as part of a going concern —such as treating the gross receipts from its use in both intrastate and interstate commerce as an index or measure of its value — and if the means do not involve any discrimination against interstate commerce and the tax amounts to no more than what would be legitimate as an ordinary tax upon the property, valued with reference to its use, the tax is not open to attack as restraining or burdening such commerce.””
4 later decisions quote this exact passage · from the majority““Such taxes shall be in lieu of all other taxes and licenses, state, county and municipal, upon the property above enumerated of such companies; ...””
1 later decision quote this exact passage · from the majoritye.g. Alward v. Johnson
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.