Trinova Corporation v. Michigan Department of Treasury’s Empirical Analysis
1991
Citation profile
7 federal appellate · 1 district · 123 state decisions
How this case has been cited
Cited by 168 later decisions (7 by the Supreme Court) — most recently February 2024 · most notably Quill Corporation v. North Dakota Heitkamp (1992), Itel Containers International Corp. v. Huddleston (1993)
7 federal appellate · 1 district · 123 state decisions — followed in 23 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 Complete Auto Transit, Inc. v. Brady · Container Corp. of America v. Franchise Tax Board · Boston Stock Exchange v. State Tax Commission · Mobil Oil Corp. v. Commissioner of Taxes of Vt. · Moorman Manufacturing Co. v. Bair
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 168 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“between the interstate activities and the taxing state, and a rational relationship between the income attributed to the State and the intrastate values of the enterprise.'”
6 later decisions quote this exact passage · from the majority“The first, and again obvious, component of fairness in an apportionment formula is what might he called internal consistency-thal is, the formula must be such that, if applied by every jurisdiction, it would result in no more than all of the unitary business’ income being taxed. The second and more difficult requirement is what might be called external consistency—the factor or factors used in the apportionment formula must actually reflect a reasonable sense of how income is generated. [Container Corp. of Am. v. Franchise Tax Bd., supra, 463 U.S. at 169 , 103 S.Ct. at 2942 , 77 L.Ed. 2d at 556 .]”
2 later decisions quote this exact passage · from the concurrence“Our decision today does not prevent the States from structuring their tax systems to encourage the growth and development of intrastate commerce and industry. Nor do we hold that a State may not compete with other States for a share of interstate commerce; such competition lies at the heart of a free trade policy. We hold only that in the process of competition no State may dis-criminatorily tax the products manufac tured or the business operations performed in any other State.”
2 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.