Hormel v. Helvering’s Empirical Analysis
312 U.S. 552 · 1941
Citation profile
2,198 federal appellate · 64 district · 223 state decisions
How this case has been cited
Cited by 3,526 later decisions (64 by the Supreme Court) — most recently June 2025 · most notably United States v. Olano (1993), Singleton v. Wulff (1976)
2,198 federal appellate · 64 district · 223 state decisions — followed in 27 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
reviewedHelvering v. Hormel (from Eighth Circuit Court of Appeals)
Relationships
Relies on Helvering v. Clifford · Helvering v. Gowran · Vandenbark v. Owens-Illinois Glass Co. · Helvering v. Tex-Penn Oil Co.
Cited together with Singleton v. Wulff · United States v. L. A. Tucker Truck Lines, Inc. · United States v. Atkinson · United States v. United States Gypsum Co. · Erie Co v. Tompkins
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 3,526 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Rules of practice and procedure are devised to promote the ends of justice, not to defeat them. A rigid and undeviating judicially declared practice under which courts of review would invariably and under all circumstances decline to consider all questions which had not previously been specifically urged would be out of harmony with this policy. Orderly rules of procedure do not require sacrifice of the rules of fundamental justice.”
146 later decisions quote this exact passage · from the majority“would be a plain miscarriage of justice,”
30 later decisions quote this exact passage · from the majority“* * * In general, it is the function of the Board to determine the facts of a tax controversy on issues raised before it and to apply the law to these facts; and it is the function of the reviewing court to decide whether the Board has applied the correct rule of law.”
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.