Railroad Company v. National Bank’s Empirical Analysis
102 U.S. 14 · 1880
Citation profile
90 federal appellate · 19 district · 88 state decisions
How this case has been cited
Cited by 324 later decisions (33 by the Supreme Court) — most recently July 1993 · most notably Davis v. Wakelee (1895), Liverpool & Great Western Steam Co. v. Phenix Insurance (1889)
90 federal appellate · 19 district · 88 state decisions — followed in 29 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 Swift v. Tyson · Wayman v. Southard · Tennessee v. Davis · Oates v. National Bank
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 324 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The decisions oí the New York court which we are asked to follow in determining the rights of the parties under a contract there made are not in exposition of any legislative enactment of that state. They express the opinion of that court, not as to the rights, of parties under any law local'to that' state, but as to their rights under the general commercial law existing throughout the Union, except where, it may have been modified or changed by some local statute. It is a la.w not peculiar to one state, or dependent upon local authority, but one arising out of the usages of the commercial world.” This is very pertinent to the case in hand, and furnishes a complete answer to the contention that the question at issue is governed by the decisions of the supreme court of Pennsylvania because this, state is the place where the contracts were made and where they are to be performed. The”
4 later decisions quote this exact passage · from the majority““The transfer by indorsement to a creditor of negotiable paper before maturity, merely for an antecedent debt, although it is without his express agreement for indulgence, is- not an improper use of such paper, and is as much in the usual course of commercial business as its transfer in payment of the debt. In neither case is the bona fide holder affected by equities or defenses between prior parties of which he had no notice.””
3 later decisions quote this exact passage · from the majority““In the ordinary use of language, it will hardly he contended that 'the decisions of the courts constitute laws. The laws of a state are usually understood to mean the rules and enactments promulgated by the legislative authority thereof, or long-established local customs having the force (of laws. And we have not the slightest, difficulty in holding that this section, upon 'it's true intendment and construction, is strictly limited to local statutes and local usages of the character before stated, and does not extend to contracts and other instruments of a commercial nature, the true interpretation and effect whereof are to be sought, not in the decisions of local tribunals, but in the general principles and doctrines of commercial jurisprudence.””
2 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.