New York Rapid Transit Corporation v. City of New York Brooklyn & Queens Transit Corporation’s Empirical Analysis
303 U.S. 573 · 1938
Citation profile
40 federal appellate · 23 district · 168 state decisions
How this case has been cited
Cited by 334 later decisions (56 by the Supreme Court) — most recently July 2023 · most notably Shapiro v. Thompson (1969), Lehnhausen v. Lake Shore Auto Parts Co. (1973)
40 federal appellate · 23 district · 168 state decisions — followed in 32 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 Royster Guano Co v. Commonwealth of Virginia · Carmichael v. Southern Coal & Coke Co. · United States v. Butler · Western Live Stock v. Bureau of Revenue · Magoun v. Illinois Trust & Savings Bank
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 334 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"No question is or could be made ... as to the right of a state, or a municipality with properly delegated powers, to enact laws or ordinances, based on reasonable classification of the objects of the legislation or of the persons whom it affects. `Equal protection' does not prohibit this. Although the wide discretion as to classification retained by a legislature, often results in narrow distinctions, these distinctions, if reasonably related to the object of the legislation, are sufficient to justify the classification. Indeed, it has long been the law under the 14th Amendment that `a distinction in legislation is not arbitrary, if any state of facts reasonably can be conceived that would sustain it....' `The rule of equality permits many practical inequalities.' `What satisfies this equality has not been and probably never can be precisely defined.' "The power to make distinctions exists with full vigor in the field of taxation, where no `iron rule' of equality has ever been enforced upon the states. A state may exercise a wide discretion in selecting the subjects of taxation `particularly as respects occupation taxes.'"”
3 later decisions quote this exact passage · from the majority““* * * Taxes are repeatedly imposed on a group or class without regard to responsibility for the creation or relief of the conditions to be remedied. * * * There need be no relation between the class of taxpayers and the purpose of the appropriation. “* * * The ‘object’ of the Local Laws under consideration, as in the case with most tax statutes, was obviously to secure revenue. In some cases a classification of taxpayers may be upheld as having a fair and substantial relation to a constitutional non-fiscal object [citing cases], but it is not constitutionally necessary that the classification be related to the appropriation. * * * We conclude, therefore, that the provisions of the legislation earmarking the funds collected are not of importance in determining whether or not the classification of the challenged acts is discriminatory.””
2 later decisions quote this exact passage · from the majoritye.g. Hassler v. Engberg · Dicks v. Naff“It has long been the law under the Fourteenth Amendment that `a distinction in legislation is not arbitrary, if any state of facts reasonably can be conceived that would sustain it.'”
2 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.