Department of Revenue of Ore. v. ACF Industries, Inc.’s Empirical Analysis
1994
Citation profile
201 federal appellate · 26 district · 88 state decisions
How this case has been cited
Cited by 533 later decisions (36 by the Supreme Court) — most recently April 2025 · most notably Gustafson v. Alloyd Co. (1995), Barnhart Commissioner of Social Security v. Walton (2002)
201 federal appellate · 26 district · 88 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
reviewedACF Industries, Inc. v. Department of Revenue of Oregon (from Ninth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 1341 · 4 U.S.C. § 111
Relies on Rice v. Santa Fe Elevator Corp. · Cipollone v. Liggett Group, Inc. · United Sav. Assn. of Tex. v. Timbers of Inwood Forest Associates, Ltd. · Griffin v. Oceanic Contractors, Inc. · Davis v. Michigan Department of the Treasury
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 533 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“identical words used in different parts of the same act are intended to have the same meaning.”
11 later decisions quote this exact passage“(b) The following acts unreasonably burden and discriminate against interstate commerce, and a State, subdivision of a State, or authority acting for a State or subdivision of a State may not do any of them: (1) Assess rail transportation property at a value that has a higher ratio to the true market value of the rail transportation property than the ratio that the assessed value of other commercial and industrial property in the same assessment jurisdiction has to the true market value of the other commercial and industrial property. (2) Levy or collect a tax on an assessment that may not be made under paragraph (1) of this subsection. (3) Levy or collect an ad valorem property tax on rail transportation property at a tax rate that exceeds the tax rate applicable to commercial and industrial property in the same assessment jurisdiction. (4)Impose another tax that discriminates against a rail carrier providing transportation subject to the jurisdiction of the Board under this part.”
9 later decisions quote this exact passage · from the majority“'are easy prey for State and local tax assessors' in that they are 'nonvoting, often nonresident, targets for local taxation' who cannot easily remove themselves from the locality.”
9 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.