Nashville St Ry v. Wallace’s Empirical Analysis
288 U.S. 249 · 1933
Citation profile
183 federal appellate · 71 district · 220 state decisions
How this case has been cited
Cited by 935 later decisions (164 by the Supreme Court) — most recently June 2025 · most notably District of Columbia Court of Appeals v. Feldman (1983), Franchise Tax Board of the State of California v. Construction Laborers Vacation Trust for Southern California (1983)
183 federal appellate · 71 district · 220 state decisions — followed in 40 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.
Relationships
Relies on Village of Euclid Ohio v. Ambler Realty Co · Pierce v. Society of the Sisters of the Holy Names of Jesus and Mary Same · Massachusetts v. Mellon · Old Colony Trust Co. v. Commissioner · Field v. Clark
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 935 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]here can be no valid objection to the taxation of the exercise of any right or power incident to appellant's ownership of the gasoline, which falls short of a tax directly imposed on its use in interstate commerce, deemed forbidden in Helson v. Kentucky, [ 279 U.S. 245 , 49 S.Ct. 279 , 73 L.Ed. 683 (1929)], supra. Here the tax is imposed on the successive exercise of two of those powers, the storage and withdrawal from storage of the gasoline. Both powers are completely exercised before use of the gasoline in interstate commerce begins. The tax imposed upon their exercise is therefore not one imposed on the use of the gasoline as an instrument of commerce and the burden of it is too indirect and remote from the function of interstate commerce itself to transgress constitutional limitations.... ... [T]he levy is a tax, not a toll or charge for use of the highways... .”
6 later decisions quote this exact passage · from the majority“'valuable legal rights [must] be directly affected to a specific and substantial degree'”
4 later decisions quote this exact passage · from the majority““The states are left free to regulate their own judicial procedure. Hence changes merely in the form or method of procedure by which federal rights are brought to final adjudication in the state courts are not enough to preclude review of the adjudication by this Court, so long as the case retains the essentials of an adversary proceeding, involving a real, not a hypothetical controversy, which is finally determined by the judgment below.” (Italics supplied.)”
3 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.