Enochs v. Williams Packing & Navigation Co.’s Empirical Analysis
1962
Citation profile
836 federal appellate · 370 district · 73 state decisions
How this case has been cited
Cited by 2,571 later decisions (32 by the Supreme Court) — most recently August 2023 · most notably United States v. Janis (1976), Samuels v. J Mackell Fernandez (1971)
836 federal appellate · 370 district · 73 state decisions — followed in 15 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.
Appellate journey
reviewedJ. L. Enochs, District Director of Internal Revenue v. Williams Packing & Navigation Co., Inc. (from Fifth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 3111 (Federal Insurance Contributions Act) · 26 U.S.C. § 3121 (Federal Insurance Contributions Act) · 26 U.S.C. § 3301 (Federal Unemployment Tax Act) · 26 U.S.C. § 6212 · 26 U.S.C. § 7421 · 28 U.S.C. § 1341
Relies on Great Lakes Dredge & Dock Co. v. Huffman · United States v. Silk · Miller v. Standard Nut Margarine Co. · Matthews v. Rodgers
Cited together with Bob Jones University v. Simon · Alexander v. "Americans United" Inc. · Miller v. Standard Nut Margarine Co. · Flora v. United States · South Carolina v. Regan
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 2,571 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“if it is clear that under no circumstances could the Government ultimately prevail”
138 later decisions quote this exact passage · from the majority“[N]o suit for the purpose of restraining the assessment or collection of any tax shall be maintained in any court by any person, whether or not such person is the person against whom such tax was assessed.”
85 later decisions quote this exact passage · from the majority““‘The existing practice of the Federal courts in entertaining tax-injunction suits against State officers makes it possible for foreign corporations doing business in such States to withhold from them . . . taxes in such vast amounts and for such long periods of time as to seriously disrupt State and county finances. The pressing needs of these States for this tax money is so great that in many instances they have been compelled to compromise these suits, as a result of which substantial portions of the tax have been lost to the States ....’” 370 U.S. at 7, n. 6 (emphasis added).”
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.