Federal Compress & Warehouse Co. v. McLean’s Empirical Analysis
291 U.S. 17 · 1934
Citation profile
23 federal appellate · 7 district · 94 state decisions
How this case has been cited
Cited by 212 later decisions (50 by the Supreme Court) — most recently April 2017 · most notably Rice v. Santa Fe Elevator Corp. (1947), Pike v. Bruce Church, Inc. (1970)
23 federal appellate · 7 district · 94 state decisions — followed in 22 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 Coe v. Town of Errol · Nashville St Ry v. Wallace · Dahnke-Walker Milling Co. v. Bondurant · Arkadelphia Milling Co v. St Louis Southwestern Ry Co Hasty · Utah Power & Light Co. v. Pfost
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 212 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Appellant’s license .under the United States Warehouse Act did not confer upon it immunity from state taxation, for neither the appellant nor its business was, by force of the license, converted into an agency or instrumentality of the federal government. The Warehouse Act [ 7 U.S.C.A. § 241 et seq.] confers upon licensees certain privileges and secures to the national government, by means of the licensing provisions, a measure of control over those engaged in the business of Storing agricultural products who find it advantageous to apply for the license. The government exercises that control in the furtherance of a governmental purpose to secure fair and uniform business practices. But the appellant, in the enjoyment of the privilege, is engaged in its own behalf, not the government’s, in the conduct of a private business for profit. It can no longer be thought that the enjoyment of a privilege conferred by either the national or a state government upon the individual, even though to promote some governmental policy, relieves him from the taxation by the other of his property or business used or carried on in the enjoyment of the privilege or of the profits derived from it. Susquehanna Power Company v. State Tax Commission, 283 U.S. 291 , 51 S.Ct. 434 , 75 L.Ed. 1042 ; Fox Film Corporation v. Doyal, 286 U.S. 123 , 52 S.Ct. 546 , 76 L.Ed. 1010 ; Broad River Power Company v. Query, 288 U.S. 178, 180 , 53 S.Ct. 326 , 77 L.Ed. 685 .” ****** “The mere extension of control over a”
4 later decisions quote this exact passage · from the majority“It is clear by all accepted tests the cotton, while in appellant's warehouse, has not begun to move in interstate commerce . . ..”
2 later decisions quote this exact passage · from the majority“When it comes to rest there, its interstate journey . . . comes to an end, and although in the ordinary course of business the cotton would ultimately reach points outside the state, its journey interstate does not begin and so it does not become exempt from local tax until its shipment to points of destination outside the state. Before shipping orders are given, it has no ascertainable destination without the state. . . . Property thus withdrawn from transportation, whether intrastate or interstate, until restored to a transportation movement interstate , has often been held to be subject to local taxation. (citations omitted) (emphasis added). Ibid at 21, 54 S.Ct. at 268 .”
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.