Central Railroad Company of Pennsylvania v. Commonwealth of Pennsylvania’s Empirical Analysis
1962
Citation profile
3 federal appellate · 159 state decisions
How this case has been cited
Cited by 187 later decisions (14 by the Supreme Court) — most recently July 2021 · most notably McLaughlin v. Florida (1964), Japan Line, Ltd. v. County of Los Angeles (1979)
3 federal appellate · 159 state decisions — followed in 26 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.
Relationships
Applies 28 U.S.C. § 1257
Relies on Allied Stores of Ohio, Inc. v. Bowers · H. P. Hood & Sons, Inc. v. Du Mond · Coe v. Town of Errol · Wisconsin v. J. C. Penney Co. · Pullman's Palace-Car Co v. Commonwealth of Pennsylvania
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 187 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[M]ultiple taxation is possible only if there exists some jurisdiction, in addition to the domicile of the taxpayer, which may constitutionally impose an ad valorem tax.”
5 later decisions quote this exact passage · from the majority““The rule which permits taxation by two or more states on an apportionment basis precludes taxation of all of the property by the state of the domicile. See, Union Refrigerator Transit Co. v. Commonwealth of Kentucky 199 U.S. 194 , 26 S.Ct. 36 , 50 L.Ed. 150 . Otherwise there would be multiple taxation of interstate operations and the tax would have no relation to the opportunities, benefits, or protection which the taxing state gives those operations.””
4 later decisions quote this exact passage · from the dissent“The United States Constitution limits Texas’ power to tax property which has acquired a tax situs outside of the State. A tax on instrumentalities of commerce raises two constitutional concerns. First, due process requires at least a minimal jurisdictional connection with a state. The due process limitation on taxing instrumentalities of commerce demands that the tax in practical operation bear some relation to opportunities, benefits, or protection conferred or afforded by the taxing state. The second constitutional issue is whether a tax represents a burden on interstate commerce. The concern here is with the potential for double taxation if every state is free to tax the property at full value.”
3 later decisions quote this exact passage · from the dissent
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.