United States v. County of Fresno’s Empirical Analysis
1977
Citation profile
93 federal appellate · 24 district · 126 state decisions
How this case has been cited
Cited by 374 later decisions (48 by the Supreme Court) — most recently January 2025 · most notably Montana v. United States (1979), Harper v. Virginia Department of Taxation (1993)
93 federal appellate · 24 district · 126 state decisions — followed in 21 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
Relies on M'Culloch v. State of Maryland · Hill v. United Brotherhood of Carpenters & Joiners, Local 25 · United States v. Allegheny County Pa · James v. Dravo Contracting Co. · Graves v. People of State of New York O'Keefe
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 374 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the economic burden on a federal function of a state tax imposed on those who deal with the Federal Government does not render the tax unconstitutional so long as the tax is imposed equally on the other similarly situated constituents of the State.”
13 later decisions quote this exact passage · from the majority“Although the tax is imposed by the appellee counties on renters of real property only if the owner is exempt from taxation — and consequently is not imposed on the vast majority of renters of real property in California— the tax is not for that reason discriminatory. In this respect this case is governed by United States v. City of Detroit, 355 U. S. 466 (1958). There the city of Detroit imposed a use tax on those who used tax-exempt property owned by the United States. The tax was measured by the value of the property. With respect to nonexempt property, a similar tax was imposed on the owner and none on the user. In answering an argument that the tax discriminated against those dealing with the Federal Government, the Court said: "As suggested before the legislature apparently was trying to equate the tax burden imposed on private enterprise using exempt property with that carried by similar businesses using taxed property. Those using exempt property are required to pay no greater tax than that placed on private owners or passed on by them to their business lessees." Id., at 473-474. (Emphasis added.) Similarly, here the State of California imposes a property tax on owners of nonexempt property which is "passed on by them to their . . . lessees." Consequently, the appellants who rent from the Forest Service are no worse off under California tax laws than those who work for private employers and rent houses in the private sector.”
7 later decisions quote this exact passage · from the majority“A tax on the income of federal employees... if imposed only on them, could be escalated by a state so as to destroy the federal function performed by them either by making the Federal Government unable to hire anyone or by causing the Federal Government to pay prohibitively high salaries. This danger would never arise, however, if the tax is also imposed on the income and property interests of all other residents and voters of the State.”
4 later decisions quote this exact passage · from the concurrence
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.