Reich v. Collins’s Empirical Analysis
1994
Citation profile
35 federal appellate · 9 district · 114 state decisions
How this case has been cited
Cited by 199 later decisions (8 by the Supreme Court) — most recently June 2025 · most notably John Aldens v. Maine (1999), Reynoldsville Casket Co. v. Hyde (1995)
35 federal appellate · 9 district · 114 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
Applies 4 U.S.C. § 111
Relies on National Association for Advancement of Colored People v. State of Alabama Patterson · M'Culloch v. State of Maryland · Ford Motor Co. v. Department of Treasury · Mahan & Rowsey, Inc. v. Oklahoma Natural Gas · United States v. Detroit Timber & Lumber Co.
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 199 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In a long line of cases, this Court has established that due process requires a “clear and certain” remedy for taxes collected in violation of federal law. A State has the flexibility to provide that remedy before the disputed taxes are paid (prede-privation), after they are paid (postdeprivation), or both. But what it may not do . . .is hold out what plainly appears to be a “clear and certain” postdeprivation remedy and then declare, only after the disputed taxes have been paid, that no such remedy exists.”
7 later decisions quote this exact passage · from the majority“A State is free . . . to reconfigure its remedial scheme [regarding tax refunds] over time, to fit its changing needs. Such choices are generally a matter only of state law.”
4 later decisions quote this exact passage · from the majority“a denial by a state court of a recovery of taxes exacted in violation of the laws or Constitution of the United States by compulsion is itself in contravention of the Fourteenth Amendment, the sovereign immunity States traditionally enjoy in their own courts notwithstanding.”
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.