Allen v. Regents of University System of Georgia’s Empirical Analysis
304 U.S. 439 · 1938
Citation profile
132 federal appellate · 30 district · 44 state decisions
How this case has been cited
Cited by 341 later decisions (44 by the Supreme Court) — most recently August 2016 · most notably Curtis Publishing Co. v. Butts (1967), Land US v. Dollar (1947)
132 federal appellate · 30 district · 44 state decisions — followed in 15 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
reviewedRegents of University System of Georgia v. Page (from Fifth Circuit Court of Appeals)
Relationships
Relies on Miller v. Standard Nut Margarine Co. · Philadelphia Co. v. Stimson · Anniston Mfg Co v. Davis · South Carolina v. United States · Pennoyer v. McConnaughy
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 341 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The statute [§ 7421 of Internal Revenue Code of 1954] is inapplicable in exceptional cases where there is no plain, adequate, remedy at law. This is such a case, for here the assessment is not of a tax payable by respondent but of a penalty for failure to collect it from another.””
2 later decisions quote this exact passage · from the majority““The University of Georgia (or Georgia School of Technology) being an instrumentality of the government of the State of Georgia, contends that it is not liable for any admission tax. The amount stated as a tax is so stated because the University is required to do so by Treasury regulations pending a decision as to its liability in this respect. This amount is collected by the University as a part of the admission and will be retained as such unless it is finally determined that the University is itself liable for the tax.””
1 later decision quote this exact passage · from the majoritye.g. Mazzella v. Yoke“If it be conceded that the education of its prospective citizens is an essential governmental function of [a state], as necessary to the preservation of the State as is the maintenance of its executive, legislative, and judicial branches, it does not follow that if the State elects to provide the funds for any of these purposes by conducting a business, the application of the avails in aid of necessary governmental functions withdraws the business from the field of federal taxation.”
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.