United States v. Safety Car Heating & Lighting Co.’s Empirical Analysis
297 U.S. 88 · 1936
Citation profile
184 federal appellate · 23 district · 13 state decisions
How this case has been cited
Cited by 376 later decisions (20 by the Supreme Court) — most recently June 2024 · most notably Rutkin v. United States (1952), Hassett v. Welch (1938)
184 federal appellate · 23 district · 13 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
reviewedUnited States v. Safety Car Heating & Lighting Co. (from Third Circuit Court of Appeals)
Relationships
Relies on Eisner v. Macomber · North American Oil Consolidated v. Burnet · Lucas v. American Code Co. · Towne v. Eisner · Doyle v. Mitchell Bros.
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 376 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Income within the meaning of the Sixteenth Amendment is the fruit that is born of capital, not the potency of fruition. With few exceptions, if any, it is income as the word is known in the common speech of men.””
4 later decisions quote this exact passage · from the majority““We have said of that act that it reveals in its provisions an intention on the part of Congress to reach ‘pretty much every sort of income subject to the federal power.’ Helvering v. Stockholms Enskilda Bank, 293 U.S. 84, 89 , 55 S.Ct. 50, 52 , 79 L.Ed. 211 .””
1 later decision quote this exact passage · from the majority“* * * The case is not to be confused with one where the basis of the suit is an injury to capital, with the result that the recovery is never income, no matter when collected. * *”
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.