United States v. Stone & Downer Co.’s Empirical Analysis
274 U.S. 225 · 1927
Citation profile
93 federal appellate · 3 district · 46 state decisions
How this case has been cited
Cited by 397 later decisions (19 by the Supreme Court) — most recently February 2026 · most notably Commissioner v. Sunnen (1948), United States v. American Trucking Associations (1940)
93 federal appellate · 3 district · 46 state decisions — followed in 13 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 Duplex Printing Press Co. v. Deering · Gould v. Gould · Pennsylvania Railroad Company v. International Coal Mining Company · United States v. Merriam · New Orleans v. Citizens' Bank
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 397 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“* * * The effect of adjudicated controversies arising over classification of importations may well be distinguished from the irrevocable effect of ordinary tax litigation tried in the regular courts. 8 There of course should be an end of litigation as well in customs matters as in other tax cases, but circumstances justify limiting the finality of the conclusion in customs controversies to the identical importation. The business of importing is carried on by large houses between whom and the government there are innumerable transactions, as here, for instance, in the enormous importations of wool, and there are constant differences as to proper classifications of similar importations. The evidence which may be presented in one case may be much varied in the next. The importance of a classification and its far-reaching effect may not have been fully understood or clearly known when the first litigation was carried through. One large importing house may secure a judgment in its favor from the Customs Court on a question of fact as to the merchandise of a particular importation, or a question of construction in the classifying statute. If that house can rely upon a conclusion in early litigation as one which is to remain final as to it, and not to be reheard in any way, while a similar importation made by another importing house may be tried and heard and a different conclusion reached, a most embarrassing situation is presented. The importing house which has by the principle of”
6 later decisions quote this exact passage · from the majority“In this case, as in every other involving the interpretation of a statute, the intention of Congress is an all important factor. The greatest light is thrown on that intention in this case by an examination of the existing conditions and the anticipated evils against which by this legislation Congress sought to protect the country.”
2 later decisions quote this exact passage · from the majority“* * * Congress, by using the expression “commonly known as clothing wool,” indicated expressly its intention not to give to the expression “clothing wool” the commercial designation that it has when used in contrast with combing wool * *”
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.