Critzer v. United States’s Empirical Analysis
597 F.2d 708 · 1979
Citation profile
8 federal appellate ·
How this case has been cited
Cited by 40 later decisions — most recently April 2019 · most notably United States v. Anderson (1980), Dillon v. United States (1986)
8 federal appellate ·
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 25 U.S.C. § 331 (White Earth Reservation Land Settlement Act of 1985) · 25 U.S.C. § 461 · 25 U.S.C. § 465
Relies on Mescalero Apache Tribe v. Jones · Squire v. Capoeman · United States v. Rickert · Oklahoma Tax Comm'n v. United States · Superintendent of Five Civilized Tribes v. Commissioner
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 40 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"we do not say that the land is not of some value in helping create income such as that realized from the operation of a motel. Even the Government admits that it might be appropriate in certain instances to allocate income based upon the relative value of the land vis-a-vis any improvements or services. However, we do not reach this problem of allocation in the matter of Mrs. Critzer. That issue remains for yet another case on another day, since plaintiff has not raised it in the case at bar. [ 220 Ct. Cl. at 53 , 597 F.2d at 714 . Fn. ref. omitted. Emphasis in original.]””
4 later decisions quote this exact passage“If * * * [the taxpayer] were to sit in a telephone booth on her Indian land and sell stock and bonds by the phone from the booth, it would be ludicrous to attempt to argue that any income, so earned, was directly derived from the land.”
2 later decisions quote this exact passage“That all lands, and other property, of the band, or the members thereof, except funds held in trust by the United States, may be taxed by the State of North Carolina, to and including the tax year following the date of this Act. Such taxes shall be paid from the common funds of said band for such period, except upon such tracts as shall have been lawfully sold prior to the date when tax assessments can be made thereon under the State law. All tax assessments made pursuant to this Act on restricted allotments or undivided tribal property held in trust by the United States shall be subject to revision by the Commissioner of Indian Affairs for a period of one year following the date when such assessments are spread on the local tax rolls, but if he shall take no action thereon during said year, such assessments shall be final, but this shall not be construed to deprive any allottee of any remedy to which he would be entitled under the State law: Provided, That such restricted and undivided property shall be exempt from sale for unpaid taxes for two years from the date when such taxes become due and payable, and no penalty for delinquency in the payment of such taxes shall be charged or collected for or during said period, so that Congress may have an opportunity to make provision for the payment of such taxes if the band, or tribal, funds are found insufficient for the purpose. After the expiration of the tax year following that in which this Act is approved all lands allotted t”
1 later decision quote this exact passage
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.