People of State of Illinois Gordon v. Campbell’s Empirical Analysis
329 U.S. 362 · 1946
Citation profile
185 federal appellate · 38 district · 134 state decisions
How this case has been cited
Cited by 506 later decisions (31 by the Supreme Court) — most recently July 2014 · most notably State of New Hampshire v. State of Maine (2001), United States v. City of New Britain (1954)
185 federal appellate · 38 district · 134 state decisions — followed in 23 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
Applies 26 U.S.C. § 1400
Relies on Chas Steward Mach Co v. Davis · Helvering v. Davis · United States v. Waddill, Holland & Flinn, Inc. · Price v. United States
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 506 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“definite, and not merely ascertainable in the future by taking further steps [regarding] (1) the identity of the lienor, (2) the amount of the lien, and (3) the property to which it attaches.”
11 later decisions quote this exact passage · from the majority““Whenever any person indebted to the United States is insolvent, or whenever the estate of any deceased debtor, in the hands of the executors or administrators, is insufficient to pay all the debts due from the deceased, the debts due to the United States shall be first satisfied; and the priority established shall extend as well to cases in which a debtor, not having sufficient property to pay all his debts, makes a voluntary assignment thereof, or in which the estate and effects of an absconding, concealed, or absent debtor are attached by process of law, as to cases in which an act of bankruptcy is committed.””
7 later decisions quote this exact passage · from the majority““It has never been sufficient to show merely a general lien, effective to protect the lienor against others than the Government, but contingently on taking subsequent steps either for giving public notice of tbc lieu or for enforcing it. [Citing authorities.] The federal priority is not destroyed by state recording acts any more than by state statutes creating or otherwise affecting liens, if the lien as recorded or otherwise executed does not have the required degree of specificity and perfection. Under the decisions the test is hot, and cannot be, simply whether by his taking further steps the lienor’s rights will be enforced against others than the Government. “The long-established rule requires that the lien must be definite, and not merely ascertainable in the future by taking further steps, in at least three respects as of the crucial time. These are: (1) the identity of the lienor * * *; (2) the amount of the lien [citing authorities]; and (3) the property to which it attaches [citing authorities]. It is not enough that the lienor has power to bring these elements, or any of them, down from broad generality to the earth of specific identity. * * * “To permit the recording of the notices or the receiver’s appointment, or both, in circumstances like these, to overcome the Government’s priority would be in substance to overrule the numerous decisions cited in which liens no less ‘specific and perfected’ have been held impotent for that purpose. It would open the door, too”
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.