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← 281 U.S. 111 - Lucas v. Earl

Lucas v. Earl’s Empirical Analysis

281 U.S. 111 · 1930

Citation profile

2,375
cited by 2,375 later decisions
60
cited 60 times by the Supreme Court
22
states following
February 2025
most recently cited

1,062 federal appellate · 35 district · 53 state decisions

How this case has been cited

Cited by 2,375 later decisions (60 by the Supreme Court) — most recently February 2025 · most notably Commissioner v. Sunnen (1948), Helvering v. Clifford (1940)

1,062 federal appellate · 35 district · 53 state decisions — followed in 22 states

42101930194019501960197019801990200020102020decided

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

reviewedEarl v. Commissioner (from Ninth Circuit Court of Appeals)

Relationships

Relies on Oklahoma v. Texas · Earl v. Commissioner

Cited together with Helvering v. Horst · Helvering v. Eubank · Commissioner of Internal Revenue v. Culbertson · Oklahoma v. Texas · Blair v. Commissioner

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 2,375 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “the fruits are attributed to a different tree from that on which they grew.”
    47 later decisions quote this exact passage · from the majority
    e.g. Burnet v. Leininger · Galt v. Commissioner
  2. “The validity of the contract is not questioned, and we assume it would be unquestionable under the law of the state of California, in which the parties lived.”
    3 later decisions quote this exact passage · from the majority
    e.g. La Verne Schulz and Barbara Schulz v. Commissioner of Internal Revenue, La Verne Schulz Family Trust (A Trust), Barbara Schulz, Trustee v. Commissioner of Internal Revenue, Russell H. White and Belva J. White v. Commissioner of Internal Revenue · Schulz v. Commissioner
  3. “derived from . . . wages, or compensation for personal service, of whatever kind and in whatever form paid, . . .; also from interest . . .”
    3 later decisions quote this exact passage · from the majority
    e.g. Helvering v. Horst · Kochansky v. Commissioner

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.