United States v. Alabama’s Empirical Analysis
313 U.S. 274 · 1941
Citation profile
109 federal appellate · 24 district · 70 state decisions
How this case has been cited
Cited by 372 later decisions (17 by the Supreme Court) — most recently June 2021 · most notably Armstrong v. United States (1960), United States v. Brosnan (1960)
109 federal appellate · 24 district · 70 state decisions — followed in 19 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 Minnesota v. United States · Van Brocklin v. Anderson · New York v. Maclay · The Siren
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 372 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A proceeding against property in which the United States has an interest is a suit against the United States.”
4 later decisions quote this exact passage · from the majority““Our present inquiry is whether, assuming the validity of the state statute creating a lien as of October 1, 1936, as against other subsequent purchasers, it should be deemed invalid as against the United States. The question is not whether such a lien could be enforced against the United States. The fact that the United States had taken title and that proceedings could not be taken against the United States without its consent would protect it from such enforcement. But that immunity would not be predicated upon the invalidity of the lien. If in this instance title had been taken by the United States in the summer of 1937 after the amount of the taxes had been ascertained and the respective liens were concededly valid, still proceedings against the United States could not be prosecuted without its consent. “The government is not content with that measure of protection. The government brings this suit in the view that it is entitled to have a marketable title and it seeks to remove the liens in question as clouds upon that title which would interfere with the disposition of the lands in the future. Prom that standpoint the government asks a decree declaring the invalidity of the liens and enjoining the state from asserting any claim in the lands either adverse to the United States or to its successors in title. We think that the United States is not entitled to that relief. The United States took the conveyances with knowledge of the state law fixing the lien as of October 1s”
1 later decision quote this exact passage · from the majority““ * * * perceive no reason why the United States, albeit protected with respect to proceedings against it without its consent, should stand, so far as the existence of the liens is concerned, in any different position from that of other purchasers of lands in Alabama who take conveyances on and after the specified tax date. It is familiar practice for grantees who take title in such circumstances to see that provision is made for the payment of taxes and the Government could easily have protected itself in like manner.” 16”
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.