Flora v. United States’s Empirical Analysis
1958
Citation profile
302 federal appellate · 93 district · 30 state decisions
How this case has been cited
Cited by 971 later decisions (11 by the Supreme Court) — most recently July 2020 · most notably Flora v. United States (1960), Quill Corporation v. North Dakota Heitkamp (1992)
302 federal appellate · 93 district · 30 state decisions
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.
Appellate journey
reviewedFlora v. United States (from Tenth Circuit Court of Appeals)
Relationships
Relies on Phillips v. Commissioner · Old Colony Trust Co. v. Commissioner · Dobson v. Commissioner · Phillips v. Commissioner
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 971 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) 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 penalty claimed to have been collected without authority or any sum alleged to have been excessive or in any manner wrongfully collected under the internal-revenue laws.”
26 later decisions quote this exact passage · from the majority“No suit or proceeding shall be maintained in any court for the recovery of any internal revenue tax alleged to have been erroneously or illegally assessed or collected, or of any penalty claimed to have been collected without authority, or of any sum alleged to have been excessive or in any manner wrongfully collected, until a claim for refund or credit has been duly filed with the Secretary, according to the provisions of law in that regard, and the regulations of the Secretary established in pursuance thereof.”
8 later decisions quote this exact passage · from the majority““It will be readily conceded, from what we have here stated, that the government has the right to prescribe the conditions on which it will subject itself to the judgment of the courts in the collection of its revenues. “While a free course of remonstrance and appeal is allowed within the departments before the money is finally exacted, the general government wisely made the payment of the tax claimed, whether of customs or of internal revenue, a condition precedent to a resort to the courts by the party against whom the tax is assessed. * * * If compliance with this condition requires the party aggrieved to pay the money, he must do it.””
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.