Phillips v. United States’s Empirical Analysis
346 F.2d 999 · 1965
Citation profile
16 federal appellate · 4 district ·
How this case has been cited
Cited by 36 later decisions — most recently May 1994 · most notably Carey v. National Oil Corp. (1979), Busse v. United States (1976)
16 federal appellate · 4 district ·
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. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 2006
Relies on American Packing & Provision Co. v. United States · Hammond-Knowlton v. United States · First National Bank v. United States · Stuart v. Chinese Chamber of Commerce of Phœnix · Hawkinson v. Johnston
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Here, as in many cases, the answer to the question of statutory interpretation depends on the spirit in which it is approached. Unfortunately for the plaintiff, the spirit proper to judicial consideration of a waiver of sovereign immunity is not one of generosity and broad interpretation [Citation omitted.] Faced with what is at best an absence of any evidence as to intent to waive sovereign immunity with respect to suits by non-taxpayers, we think that § 1346(a)(1) should be interpreted as not extending to such suits.””
3 later decisions quote this exact passage““The district courts shall have original jurisdiction, concurrent with the Court of Claims, of: (1) Any civil action against the United States for the recovery of any internal-revenue tax alleged to have been erroneously or illegally assessed or collected ... or any sum alleged to have been excessive or in any manner wrongfully collected under the internal-revenue laws.””
1 later decision quote this exact passage
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.