Arkla, Inc. v. United States’s Empirical Analysis
37 F.3d 621 · 1994
Citation profile
5 federal appellate · 1 district ·
How this case has been cited
Cited by 36 later decisions — most recently February 2017 · most notably 33 Fed. Cl. 474 - Stinson, Lyons & Bustamante, P.A. v. United States (1995), Joseph Dureiko Southern Pine Isle Corporation v. United States (2000)
5 federal appellate · 1 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 26 U.S.C. § 167 · 26 U.S.C. § 168 · 26 U.S.C. § 38 · 26 U.S.C. § 48 · 28 U.S.C. § 1295 · 28 U.S.C. § 1346 (Federal Tort Claims Act)
Relies on Parklane Hosiery Co. v. Shore · Montana v. United States · Commissioner v. Sunnen · Blonder-Tongue Laboratories, Inc. v. University of Illinois Foundation · Phelps Dodge Corp. v. AFL-CIO Joint Negotiating Committee
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.
“The doctrine of collateral estoppel, also called issue preclusion, bars parties to a prior lawsuit from relitigating any issues that were actually and necessarily determined by a court of competent jurisdiction in the prior suit. Parklane Hosiery Co., Inc. v. Shore, 439 U.S. 322 , 326 n. 5, 99 S.Ct. 645 , 649 n. 5, 58 L.Ed.2d 552 (1979). The doctrine serves “the dual purpose of protecting litigants from the burden of re-litigating an identical issue with the same party or his privy and of promoting judicial economy by preventing needless litigation.” Id. at 326 , 99 S.Ct. at 649. Affording a litigant more than one full and fair opportunity for judicial resolution of the same issue results in an untenable misallocation of resources. Blonder-Tongue Labs., Inc. v. University of Ill. Found., 402 U.S. 313, 328-29 , 91 S.Ct. 1434, 1442-43 , 28 L.Ed.2d 788 (1971). Collateral estoppel is appropriate only if: (1) the issue to be decided is identical to one decided in the first action; (2) the issue was actually litigated in the first action; (3) resolution of the issue was essential to a final judgment in the first action; and (4) the parties had a full and fair opportunity to litigate the issue in the first action. Mother’s Restaurant, Inc. v. Mama’s Pizza, Inc., 723 F.2d 1566, 1569 , 221 USPQ 394, 397 (Fed.Cir.1983).”
3 later decisions quote this exact passage · from the majority“(1) the issue at stake is identical to the one involved in the prior proceeding; (2) the issue was actually litigated in the prior proceeding; (3) the determination of the issue in the prior litigation must have been “a critical and necessary part” of the judgment in the first action; and (4) the party against whom collateral estoppel is asserted must have had a full and fair opportunity to litigate the issue in the prior proceeding.”
3 later decisions quote this exact passage · from the majority“[s]ection 168(f)(9) only affects the amount of a depreciation deduction once an asset is found to be subject to depreciation ... [but] does not influence whether a depreciation deduction is allowed in the first place.”
1 later decision 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.