Helvering v. Mitchell’s Empirical Analysis
303 U.S. 391 · 1938
Citation profile
650 federal appellate · 100 district · 588 state decisions
How this case has been cited
Cited by 2,158 later decisions (60 by the Supreme Court) — most recently January 2025 · most notably Sedima Sprl v. Imrex Company Inc (1985), United States v. Halper (1989)
650 federal appellate · 100 district · 588 state decisions — followed in 49 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
reviewedMitchell v. Commissioner of Internal Revenue (from Second Circuit Court of Appeals)
Relationships
Relies on Boyd v. United States · United States v. Murdock · United States Bilokumsky v. Tod · Ng Fung Ho v. White
Cited together with Helvering v. Mitchell · United States v. Halper · United States Marcus v. Hess · Kennedy v. Mendoza-Martinez · United States v. Ward
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 2,158 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Congress may impose both a criminal and a civil sanction in respect to the same act or omission; for the double jeopardy clause prohibits merely punishing twice, or attempting a second time to punish criminally, for the same offense.”
51 later decisions quote this exact passage · from the majority“primarily as a safeguard for the protection of the revenue and to reimburse the Government for the heavy expense of investigation and the loss resulting from the taxpayer's fraud.”
38 later decisions quote this exact passage · from the majority“That acquittal on a criminal charge is not a bar to a civil action by the Government, remedial in its nature, arising out of the same facts on which the criminal proceeding was based has long been settled.”
36 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.