United States v. Prudden’s Empirical Analysis
424 F.2d 1021 · 1970
Citation profile
95 federal appellate · 4 district · 8 state decisions
How this case has been cited
Cited by 141 later decisions (1 by the Supreme Court) — most recently March 2019 · most notably Beckwith v. United States (1976), United States v. Wuagneux (1982)
95 federal appellate · 4 district · 8 state decisions
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
Relies on Miranda v. State of Arizona Vignera · United States v. United States Gypsum Co. · Escobedo v. Illinois · Johnson v. State of New Jersey · Nardone v. United States
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 141 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[T]he record * * * must disclose some affirmative misrepresentation to establish the existence of fraud'”
9 later decisions quote this exact passage · from the majority““A ‘routine’ tax investigation openly commenced as such is devoid of stealth or deceit because the ordinary taxpayer surely knows that there is inherent in it a warning that the government’s agents will pursue evidence of misreporting without regard to the shadowy line between avoidance and evasions, mistake and willful omission. “Moreover, it is unrealistic to suggest that the government could or should keep a taxpayer advised as to the direction in which its necessarily fluctuating investigations lead. The burden on the government would be impossible to discharge in fact, and would serve no useful purpose.””
3 later decisions quote this exact passage · from the majority“duty to speak or where an inquiry left unanswered would be intentionally misleading.”
3 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.