Riggs v. Del Drago’s Empirical Analysis
317 U.S. 95 · 1942
Citation profile
147 federal appellate · 30 district · 469 state decisions
How this case has been cited
Cited by 831 later decisions (10 by the Supreme Court) — most recently November 2018 · most notably Spiegel's Estate v. Commissioner of Internal Revenue (1949), Harrison v. Northern Trust Co. (1943)
147 federal appellate · 30 district · 469 state decisions — followed in 41 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 Phillips v. Commissioner · Knowlton v. Moore · Phillips v. Commissioner · New York Trust Co. v. Eisner
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 831 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“that Congress intended that the federal estate tax should be paid out of the estate as a whole and that the applicable state law as to the devolution of property at death should govern the distribution of the remainder and the ultimate impact of the tax.”
33 later decisions quote this exact passage · from the majority“"Reimbursement out of estate. If the tax or any part thereof is paid by, or collected out of that part of the estate passing to or in the possession of, any person other than the executor in his capacity as such, such person shall be entitled to reimbursement out of any part of the estate still undistributed or by a just and equitable contribution by the persons whose interest in the estate of the decedent would have been reduced if the tax had been paid before the distribution of the estate or whose interest is subject to equal or prior liability for the payment of taxes, debts, or other charges against the estate, it being the purpose and intent of this subchapter (§§ 800 to 931 of this title) that so far as is practicable and unless otherwise directed by the will of the decedent the tax shall be paid out of the estate before its distribution."”
3 later decisions quote this exact passage · from the majority““The Federal estate tax, as its name indicates, a tax upon the estate as a whole and is payable by the executor or administrator, but how its burden is to be apportioned as among the beneficiaries of and persons interested in the taxed estate is a question to be determined by the law of the jurisdiction in which the estate is being administered. In other words, the ultimate impact of the Federal estate tax is governed by the applicable state law.””
3 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.