American Oil Co. v. Neill’s Empirical Analysis
1965
Citation profile
33 federal appellate · 8 district · 79 state decisions
How this case has been cited
Cited by 154 later decisions (19 by the Supreme Court) — most recently July 2025 · most notably Quill Corporation v. North Dakota Heitkamp (1992), National Bellas Hess Incorporated v. Department of Revenue of State of Illinois (1967)
33 federal appellate · 8 district · 79 state decisions — followed in 17 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 Wisconsin v. J. C. Penney Co. · Miller Bros. v. Maryland · Lawrence v. State Tax Commission · General Motors Corporation v. Washington · McLeod v. J. E. Dilworth Co.
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 154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"`When passing on the constitutionality of a state taxing scheme it is firmly established that this Court concerns itself with the practical operation of the tax, that is, substance rather than form. (Citations omitted). This approach requires us to determine the ultimate effect of the law as applied and enforced by a State or, in other words, to find the operating incidence of the tax.'”
4 later decisions quote this exact passage · from the majority“give (the state court's) finding great weight in determining the natural effect of a statute, and if it is consistent with the statute's reasonable interpretation it will be deemed conclusive.”
3 later decisions quote this exact passage · from the majority“Granted that when a corporation, pursuant to permission given, enters a State and proceeds to do local business the “link” is strong. In such instances there is a strong inference that it exists between the State and transactions which result in economic benefits obtained from a source within the State’s territorial limits. The corporation can, however, exempt itself by a clear showing that there are no in-state activities connected with out-of-state sales. In such instances, the transactions are said to be “dissociated from the local business,” Norton Co. v. Department of Revenue, supra, 340 U.S. at 537 [ 71 S.Ct. at 380 ], 95 L.Ed. at 521, and therefore may not, consistent with due process, be taxed.”
2 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.