United States v. Roessling’s Empirical Analysis
280 F.2d 933 · 1960
Citation profile
28 federal appellate · 3 district · 1 state decisions
How this case has been cited
Cited by 46 later decisions — most recently April 1994 · most notably Kimbell Foods, Inc. v. Republic National Bank (1977), Matagorda County v. Russell Law (1994)
28 federal appellate · 3 district · 1 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.
Relationships
Relies on United States v. City of New Britain · United States v. Allegheny County Pa · United States v. Brosnan · Sra v. State of Minnesota · City of New Brunswick v. United States
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“No state or county can tax the property interests of the United States in the absence of congressional consent. United States v. Allegheny County, 1944, 322 U.S. 174, 191 , 64 S.Ct. 908 , 88 L.Ed. 1209 . There is no constitutional prohibition against a state or county assessing taxes against property on which the United States holds a lien on the basis of the full value of that property, but, in the absence of congressional consent, the state or county is without authority to enforce the collection of the taxes thus assessed so as to destroy the pre-existing federal lien. City of New Brunswick v. United States, supra, 276 U.S. 547, 566 , 48 S.Ct. 371 , 72 L.Ed. 693 ; S.R.A., Inc. v. State of Minnesota, 1946, 327 U.S. 558, 569 , 66 S.Ct. 749 , 90 L.Ed. 851 ; compare Bancroft Inv. Corporation v. City of Jacksonville, 1946, 157 Fla. 546 , 27 So.2d 162 .”
3 later decisions quote this exact passage““It is well established that, in the absence of a controlling federal statute, the priority of federally created tax liens is determined by the rule that a lien first in time is first in right. United States v. City of New Britain, 1954, 347 U.S. 81 , 85, 74 S.Ct. 367 , 98 L.Ed. 520 ; Michigan v. United States, 1943, 317 U.S. 338 , 340, 63 S.Ct. 302 , 87 L.Ed. 312 . That rule governing the priority of federal tax liens has been applied to federal mortgage liens as well. City of New Brunswick v. United States, 1928, 276 U.S. 547 , 555, 48 S.Ct. 371 , 72 L.Ed. 693 ; United States v. Latrobe Construction Co., 8 Cir., 1957, 246 F.2d 357 , 364; Southwest Engine Co. v. United States, 10 Cir., 1960, 275 F.2d 106 , 107.””
1 later decision quote this exact passage
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.