Simonson v. Granquist’s Empirical Analysis

Citation profile

74 federal appellate · 23 district · 9 state decisions

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 295 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “broad aim of the Act to provide for the conservation of the estates of insolvents to the end that there may be as equitable a distribution of assets as is consistent with the type of claims involved.”

   22 later decisions quote this exact passage · from the majority
   e.g. United States ex rel. Internal Revenue Service v. Dumler · In Re Petite Auberge Village, Inc.

2. “(d)ebts owing to the United States ... as a penalty or forfeiture ... except for the amount of the pecuniary loss sustained by the act, transaction, or proceeding out of which the penalty or forfeiture arose.”

   9 later decisions quote this exact passage · from the majority
   e.g. In Re Burden · Chemical Bank New York Trust Co. v. Steamship Westhampton

3. “We cannot agree with the suggestion that the label placed upon an imposition in a revenue measure is decisive in determining its character____ We disagree, too, with the conclusion that a tax under the Constitution cannot be a penalty. Section 57j places penalties in a category quite different from debts, and the character of a penalty cannot be changed by calling it a tax. The words of the statute precisely reveal the purpose of Congress not to exercise its sovereign right to a claim against a bankrupt except to the extent that there has been a pecuniary loss.”

   1 later decision quote this exact passage · from the majority
   e.g. United States Department of Energy v. West Texas Marketing Corp.