United States v. Rizzo’s Empirical Analysis
297 U.S. 530 · 1936
Citation profile
23 federal appellate · 9 district · 3 state decisions
How this case has been cited
Cited by 48 later decisions (1 by the Supreme Court) — most recently April 1987 · most notably Sims v. Rives (1936), Burke v. Mingori (1942)
23 federal appellate · 9 district · 3 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.
Appellate journey
reviewedthe decision below (from Third Circuit Court of Appeals)
Relationships
Relies on Southern Pac Co v. Bogert · United States v. One Ford Coupe Automobile · The Lottawanna · Collins v. Miller · Ex Parte Tyler
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Second. Rizzo contends that the tax sought to be recovered is a penalty imposed for violation of the National Prohibition Act * * *; hence uncollectible, because of the repeal of the Eighteenth Amendment. United States v. Chambers, 291 U.S. 217 , 54 S.Ct. 434 , 78 L.Ed. 763 , 89 A.L.R. 1510 . But this tax is not a penalty. It is the basic tax upon distilled spirits, irrespective of their legal or illegal origin. United States v. One Ford Coupe, 272 U.S. 321, 328 , 47 S.Ct. 154 , 71 L.Ed. 279 , 47 A.L.R. 1025 ; Various Items of Personal Property v. United States, 282 U.S. 577, 579 , 51 S.Ct. 282 , 75 L.Ed. 558 . * * *"”
1 later decision quote this exact passage · from the majority““ * * * A lien attaches to alcohol ‘as soon as it is in existence as such’ and continues until the tax is paid. Rev.Stat. § 3248 ( 26 U.S.C.A. § 1150 (c), 1158(b) (1)) and section 3251; Thompson v. United States, 142 U.S. 471, 474 , 12 S.Ct. 299 , 35 L.Ed. 1084 . That lien is valid against all transferees, without assessment, distraint or other administrative proceedings. Alkan v. Bean, 1 Fed.Cas. page 418, No. 202; United States v. Turner, 28 Fed. Cas. page 232 , No. 16,548.””
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.