McCardle v. Indianapolis Water Co.’s Empirical Analysis
272 U.S. 400 · 1926
Citation profile
37 federal appellate · 63 district · 167 state decisions
How this case has been cited
Cited by 392 later decisions (41 by the Supreme Court) — most recently May 2002 · most notably Kimball Laundry Co. v. United States (1949), Los Angeles Gas Electric Corporation v. Railroad Commission of California (1933)
37 federal appellate · 63 district · 167 state decisions — followed in 36 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 Smyth v. Ames · Simpson v. Shepard · Bluefield Water Works & Improvement Co. v. Public Service Commission · State of Missouri Southwestern Bell Telephone Co v. Public Service Commission of Missouri · City of Knoxville v. Knoxville Water Co.
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 392 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“mere calculations based on averages and assumed probabilities.”
6 later decisions quote this exact passage · from the majority““There is deducted approximately 25 per cent, of estimate cost new to cover accrued depreciation. The deduction was not based on an inspection of the property. It was the result of a ‘straight line’ calculation based on age and the estimated of assumed useful life of perishable elements. The commission’s report indicates that the property is well-planned, well-' maintained, and efficient. Its chief engi-: neer inspected it, and estimated its condition by giving effect to results of the examination and to the age of the property. He deducted about 6 per cent, to cover depreciation. Mr. Hagenah made an estimate of existing depreciation based on actual inspection and a consideration of the probable future life as indicated by the conditions found. He deducted less than 6 per cent. Mr. Elmes testified' that he made an inspection and estimate of all the actual depreciation. He estimated $443,044 would be required to restore the property as of appraisal date to its condition when first installed and put in practical operation. He deducted that amount. The testimony of competent valuation engineers who examined the property and made estimates in respect of its condition is to be preferred to mere calculations based on averages and assumed probabilities. The deduction made in the city’s estimate cannot be approved.””
3 later decisions quote this exact passage · from the majority““Undoubtedly, the reasonable cost of a system of waterworks, well-planned and efficient for the public service, is good evidence of its value at the time of construction. And such actual cost will continue fairly well to measure the amount to be attributed to the physical elements of the property so long as there is no change in the level of applicable prices. And, as indicated by the report of the commission, it is true that, if the tendency or trend of prices is not definitely upward or downward and it does not appear probable that there will be a substantial change of prices, then the present value of lands plus the present cost of constructing the plant, less depreciation, if any, is a fair measure of the value of the physical elements of the property. The validity of the rates in question depends on property value January 1, 1924, and for a reasonable time following. While the values of such properties do not vary with frequent minor fluctuations in the prices of material and labor required to produce them, they are affected by and generally follow the relatively permanent levels and trends of such prices.””
2 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.