United States v. National Bank of Commerce’s Empirical Analysis
1985
Citation profile
461 federal appellate · 169 district · 69 state decisions
How this case has been cited
Cited by 1,730 later decisions (9 by the Supreme Court) — most recently April 2025 · most notably United States v. Craft (2002), Cleveland v. United States (2000)
461 federal appellate · 169 district · 69 state decisions — followed in 18 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
reviewedUnited States v. National Bank of Commerce (from Eighth Circuit Court of Appeals)
Relationships
Applies 26 U.S.C. § 6331
Relies on Aquilino v. United States · Bull v. United States · Morgan v. Commissioner · Phillips v. Commissioner
Cited together with Aquilino v. United States · United States v. Rodgers · United States v. Bess · Celotex Corporation v. Catrett H · Anderson v. Liberty Lobby, Inc.
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 1,730 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If any person liable to pay any tax neglects or refuses to pay the same after demand, the amount (including any interest, additional amount, addition to tax, or assessable penalty, together with any costs that may accrue in addition thereto) shall be a lien in favor of the United States upon all property and rights to property, whether real or personal, belonging to such person.”
81 later decisions quote this exact passage · from the majority“'creates no property rights but merely attaches consequences, federally defined, to rights created under state law.' " United States v. National Bank of Commerce, 472 U.S. 713 , 722, 105 S.Ct. 2919, 2925, 86 L.Ed.2d 565 (1985) (quoting United States v. Bess, 357 U.S. 51 , 55, 78 S.Ct. 1054, 1057, 2 L.Ed.2d 1135 (1958)). See also United States v. Mitchell, 403 U.S. 190 , 197, 91 S.Ct. 1763, 1767, 29 L.Ed.2d 406 (1971) ("In the determination of ownership, state law controls.”
22 later decisions quote this exact passage · from the majority“state law controls in determining the nature of the legal interest which the taxpayer had in the property.”
17 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.