Coolidge v. Long’s Empirical Analysis

Citation profile

64 federal appellate · 9 district · 122 state decisions

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

1. ““The trust deeds are contracts within the meaning of the contract clause of the Federal Constitution. They were fully executed before the taking effect of the state law under which the- excise is claimed. The commonwealth was without authority by subsequent legislation, wheth-' er enacted under the guise of its power to tax or otherwise, to alter their effect or to impair or destroy rights which have vested under them. Appleby v. City of New York, 271 U.S. 364 , 46 S.Ct. 569 , 70 L.Ed. 992 ; Fletcher v. Peck, 6 Cranch, 87, 136 , 3 L.Ed. 162 ; Dartmouth College v. Woodward, 4 Wheat. 518, 624, 656 , 4 L.Ed. 629 ; Farrington v. Tennessee, 95 U.S. 679, 683 , 24 L.Ed. 558 ; Carondelet Canal Company v. Louisiana, 233 U.S. 362, 363, 378 , 34 S.Ct. 627 , 58 L.Ed. 1001 .””

   2 later decisions quote this exact passage · from the majority
   e.g. In Re McGrath's Estate · State Ex Rel. Fitzpatrick v. Grace

2. “Nor did the reserved powers of management of the trusts save to decedent any control over the economic benefits or the enjoyment of the property. He would equally have reserved all these powers and others had he made himself the trustee, but the transfer would not for that reason have been incomplete. The shifting of the economic interest in the trust property which was the subject of the tax was thus complete as soon as the trust was made. [Italics added.] His power to recall the property and of control over it for his own benefit then ceased and as the trusts were not made in contemplation of death, the reserved powers do not serve to distinguish them from any other gift inter vivos not subject to the tax. ...”

   1 later decision quote this exact passage · from the dissent
   e.g. Estate of Madison

3. “Section 36. This chapter shall apply only to property or interests therein passing or accruing upon the death of persons dying on or after May fourth, nineteen hundred and twenty, and as to all property and interests therein passing or accruing upon the death of persons who have died prior to said date the laws theretofore applicable shall remain in force; but so much of this chapter as relates to property or interests therein passing by deed, grant or gift completed inter vivos in contemplation of death shall apply only to such deeds, grants or gifts made on or after May twenty-seventh, nineteen hundred and twenty.”

   1 later decision quote this exact passage · from the majority
   e.g. Binney v. Long