State v. Saugen’s Empirical Analysis
1969
Citation profile
2 federal appellate · 31 state decisions
How this case has been cited
Cited by 33 later decisions — most recently July 2009 · most notably REDEVELOP. AUTH., PHILA. v. Lieberman (1975), Kafka v. Montana Department of Fish, Wildlife & Parks (2008)
2 federal appellate · 31 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 Kimball Laundry Co. v. United States · Mitchell v. United States · Arens v. Village of Rogers · Hendrickson v. State · Arens v. Village of Rogers
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 33 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The Saugen case is similarly a factually confined exception to the general rule. In Saugen , the fee owner of a liquor lounge sought to recover going-concern value when his entire fee was taken by the state. The court acknowledged that a liquor license, while an intangible property interest, is nevertheless a compensa-ble value where it is shown that the license cannot be transferred for use at another suitable location [footnote omitted]: “ ‘The present case is one where the way is open to award appellant compen sation for the going-concern value of the business. Here the condemnee was deprived of far more than the value of cold assets. The exercise of the right of eminent domain effectively destroyed appellant’s valid and unrevoked ability to continue to engage in the liquor business. The parties stipulated that absent the taking by the state, there was no evidence that appellant could not have continued to operate its lounge at the premises in question and that the appellant has gone out of the liquor business because it was unsuccessful in transferring its license to another location. It was unable to relocate because of the restricted liquor patrol limits and other peculiarities of the Minneapolis licensing situation. There is no problem here with a speculated loss because the going-concern value has been stipulated to be $17,500. Although a liquor license is a privilege visa-vis the licensing authorities, it has qualities of a property right as to third parties, and in”
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.