United States v. Sanchez’s Empirical Analysis
340 U.S. 42 · 1950
Citation profile
107 federal appellate · 9 district · 69 state decisions
How this case has been cited
Cited by 274 later decisions (23 by the Supreme Court) — most recently August 2022 · most notably Leary v. United States (1969), Grosso v. United States (1968)
107 federal appellate · 9 district · 69 state decisions — followed in 21 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 28 U.S.C. § 1252
Relies on Helvering v. Mitchell · J. W. Hampton, Jr., & Co. v. United States · Helvering v. Mitchell · A. Magnano Co. v. Hamilton · Sonzinsky 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 274 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“It is beyond serious question that a tax does not cease to be valid [under the taxing power] merely because it regulates, discourages, or even definitely deters the activities taxed. The principle applies even though the revenue obtained is obviously negligible, or the revenue purpose of the tax may be secondary. Nor does a tax statute necessarily fall because it touches on activities which Congress might not otherwise regulate.”
15 later decisions quote this exact passage · from the majority““Moreover, the Government is seeking to collect the levy by a judicial proceeding with its attendant safeguards. Compare Lipke v. Lederer, 259 U.S. 557 , [ 42 S.Ct. 549 , 66 L.Ed. 1061 ] (1922); Tovar v. Jarecki, 173 F.2d 449 (7th Cir. 1949).””
4 later decisions quote this exact passage · from the majority“Nor is the civil character of the tax imposed by § 2590(a)(2) [$100 per ounce] altered by its severity in relation to that assessed by § 2590(a)(1) [$1 per ounce]. The difference has a rational foundation. Unregistered persons are not likely to procure the required order form prior to transfer or pay the required tax. Free of sanctions, dealers would be prone to accommodate such persons in their unlawful activity. The imposition of equally severe tax burdens on such transfer-ors is reasonably adapted to secure payment of the tax by transferees or stop transfers to unregistered persons, as well as to provide an additional source from which the expense of unearthing clandestine transfers can be recovered.”
1 later decision quote this exact passage · from the majoritye.g. State v. Gallup
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.