Waterloo Distilling Corporation v. United States Various Items of Personal Property’s Empirical Analysis
282 U.S. 577 · 1931
Citation profile
83 federal appellate · 49 district · 184 state decisions
How this case has been cited
Cited by 418 later decisions (12 by the Supreme Court) — most recently April 2025 · most notably United States v. Ursery (1996), Helvering v. Mitchell (1938)
83 federal appellate · 49 district · 184 state decisions — followed in 29 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.
Appellate journey
reviewedUnited States v. Various Items of Personal Property (from Second Circuit Court of Appeals)
Relationships
Relies on United States v. One Ford Coupe Automobile · J. W. Goldsmith, Jr.-Grant Co. v. United States · United States v. La Franca · The Palmyra
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 418 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[This] forfeiture proceeding ... is in rem. It is the property which is proceeded against, and, by resort to a legal fiction, held guilty and condemned as though it were conscious instead of inanimate and insentient. In a criminal prosecution it is the wrongdoer in person who is proceeded against, convicted, and punished. The forfeiture is no part of the punishment for the criminal offense. The provision of the Fifth Amendment to the Constitution in respect of double jeopardy does not apply.”
22 later decisions quote this exact passage · from the majority“doctrine never was applied to seizures and forfeitures created by statute, in rem, cognisable on the revenue side of the exchequer. The thing is here primarily considered as the offender, or rather the offence is primarily attached to the thing ....”
3 later decisions quote this exact passage · from the majority“[a]t common law, in many cases, the right of forfeiture did not attach until the offending person had been convicted and the record of conviction produced.”
1 later decision 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.