Radio Station WOW, Inc. v. Johnson’s Empirical Analysis
326 U.S. 120 · 1945
Citation profile
173 federal appellate · 17 district · 59 state decisions
How this case has been cited
Cited by 440 later decisions (109 by the Supreme Court) — most recently June 2026 · most notably Brady v. State of Maryland (1963), Hanson v. Denckla (1958)
173 federal appellate · 17 district · 59 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 Catlin v. United States · Cobbledick v. United States · Guaranty Trust Co. v. York · Spector Motor Service, Inc. v. McLaughlin · American Surety Co. v. Baldwin
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 440 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We have no doubt of the power of the Nebraska court to adjudicate, and conclusively, the claim of fraud in the transfer of the station by the Society to WOW and upon finding fraud to direct a reconveyance of the lease to the Society. And this, even though the property consists of licensed facilities and the Society chooses not to apply for retransfer of the radio license to it, or the [Federal Communications] Commission, upon such application, refuses the retransfer. The result may well be the termination of a broadcasting station. The Communications Act does not explicitly deal with this problem, and we find nothing in its interstices that dislodges the power of the States to deal with fraud merely because licensed facilities are involved. The “public interest” with which the Commission is charged is that involved in granting licenses. Safeguarding of that interest can hardly imply that the interest of States in enforcing their laws against fraud have been nullified insofar as licensed facilities may be the instruments of fraud.”
3 later decisions quote this exact passage · from the majority“an obvious subterfuge to evade consideration of a federal issue.”
3 later decisions quote this exact passage · from the majoritye.g. Buehl v. Vaughn · Hallowell v. Keve“[Ijnsofar as the Nebraska decree orders the parties “to do all things necessary” to secure the return of the license, it hampers the freedom of the Society not to continue in broadcasting and to restrict itself, as it properly may, to its insurance business. Equally does it prevent WOW from opposing a return to the Society, or, as the United States suggests, from seeking another license of its own. These are restrictions not merely upon the private rights of parties as to whom a State court may make appropriate findings of fraud. They are restrictions upon the licensing system which Congress established. It disregards practicalities to deny that, by controlling the conduct of parties before the Communications Commission, the court below reached beyond the immediate controversy and into matters that do not belong to it.”
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.