Phillips v. Commissioner’s Empirical Analysis
283 U.S. 589 · 1931
Citation profile
782 federal appellate · 126 district · 173 state decisions
How this case has been cited
Cited by 1,871 later decisions (132 by the Supreme Court) — most recently June 2024 · most notably Board of Regents of State Colleges v. Roth (1972), Mathews v. Eldridge (1976)
782 federal appellate · 126 district · 173 state decisions — followed in 37 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
reviewedPhillips v. Commissioner (from Second Circuit Court of Appeals)
Relationships
Relies on Old Colony Trust Co. v. Commissioner · Crooks v. Harrelson · Ng Fung Ho v. White · Poe v. Seaborn
Cited together with Phillips v. Commissioner · Fuentes v. Shevin · Mathews v. Eldridge · Mitchell v. W. T. Grant Co. · Ewing v. Mytinger & Casselberry, Inc.
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 1,871 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Where only property rights are involved, mere postponement of the judicial enquiry is not a denial of due process, if the opportunity given for the ultimate judicial determination of the liability is adequate.”
49 later decisions quote this exact passage · from the majority““The amounts of the following liabilities shall * * * be assessed, collected, and paid in the same manner * * * as in the case of a deficiency in a tax imposed by this chapter * * *: “(1) The liability, at law or in equity, of a transferee of property of a taxpayer, in respect of the tax * * * imposed lipón the taxpayer by this chapter.””
8 later decisions quote this exact passage · from the majority““[T]he right of the United States to exact immediate payment and to relegate the taxpayer to a suit for recovery, is paramount.””
6 later decisions 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.