Illinois Cent Co v. State of Minnesota’s Empirical Analysis
309 U.S. 157 · 1940
Citation profile
14 federal appellate · 3 district · 70 state decisions
How this case has been cited
Cited by 137 later decisions (39 by the Supreme Court) — most recently January 2019 · most notably Complete Auto Transit, Inc. v. Brady (1977), Freeman v. Hewit (1946)
14 federal appellate · 3 district · 70 state decisions — followed in 20 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 American Sugar Refining Co. v. Louisiana · Postal Telegraph Cable Co. v. Adams · United States Express Company v. State of Minnesota · Southern Ry Co v. Watts Atlantic & Y Ry Co · Phillip Wagner v. Oscar Leser a B W
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 137 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“All roads operating in Minnesota are taxed on precisely the same, not on different bases. So far as the present incidence of the statute is concerned, the tax is laid on the net credit balances from the business of renting and borrowing cars used in Minnesota. The fact that appellant receives a larger net than others from its Minnesota activity of renting and borrowing cars and hence must pay a larger tax does not mean that Minnesota has overstepped her constitutional bounds. Appellant is not singled out for special treatment. It is not taxed on one formula; the others, on another. They are all taxed pursuant to the same formula; and the formula is adapted to the ascertainment of value of property situated in Minnesota. And appellant’s contention that the tax is discriminatory because it has only 30 miles of track and yet must pay a tax, while others with hundreds of miles may pay none is beside the point. The business taxed is not adequately measured by trackage alone. Though appellant has but few miles of track in the state, nevertheless its cars are constantly moving over other lines in Minnesota. That produces revenue. A tax on that revenue certainly bears a close relationship to appellant’s property in the state which no computation based on trackage can alter.”
1 later decision quote this exact passage · from the majority““The right of a state to tax property, although it is used in interstate commerce, is well settled. And certainly if such tax has a fair relation to the property employed in the state ... it cannot be said' to run afoul of the prohibition against state taxation on interstate commerce. As Chief Justice Fuller once said on that point, ‘... by whatever name the exaction may be called, if it amounts to no more than the ordinary tax upon property or a just equivalent therefore, ascertained by reference thereto, it is not open to attack as inconsistent with the Consitution. . . .’ ””
1 later decision quote this exact passage · from the majority“rough approximation rather than precision”
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.