Hallaway v. Thompson’s Empirical Analysis
1950
Citation profile
2 federal appellate · 92 state decisions
How this case has been cited
Cited by 96 later decisions — most recently July 2004 · most notably Robinson v. Weaver (1977), Price v. Estate of Anderson (1975)
2 federal appellate · 92 state decisions
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 45 U.S.C. § 51 (Federal Employers' Liability Act) · 45 U.S.C. § 56 (Federal Employers' Liability Act)
Relies on Mondou v. New York, New Haven & Hartford Railroad · Pedersen v. Delaware, Lackawanna & Western Railroad · Missouri Kansas Texas Pailway Company v. Sallie C Wulf · St Louis San Francisco Texas Railway Company v. Maude Seale · Phoenix Lumber Co. v. Houston Water 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 96 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he test is whether the cause of action alleged in the amended petition is `wholly based upon and grows out of a new, distinct or different transaction and occurrence'.”
5 later decisions quote this exact passage · from the majority““The obvious purpose of Article 5539b was to limit the application of the statutes of limitations to amended pleadings. It was evidently intended to modify the previously existing rule for determining whether limitation should apply to an amended pleading, as first announced in Phoenix Lumber Co. v. Houston Water Co., 94 Tex. 456 , 61 S. W. 707 . See the comment on a proposed similar statute in the Second Annual Report of the Texas Civil Judicial Council (1930) pp. 17-21, and comments on Article 5539b in 9 Tex.L. Rev. 539; 14 Tex.L.Rev. 400; 15 Tex. L.Rev. 137, 269; 18 Tex.L.Rev. 234. Article 5539b expressly provides that an amendment to a pleading shall not be subject to a plea of limitation where the amendment is not wholly based on or grows out of a new, distinct or different transaction or occurrence.””
3 later decisions quote this exact passage · from the majority““In Hanley v. Oil Capital Broadcasting Ass’n, 141 Tex. 243, 245 , 171 S.W.2d 864, 865 , the purpose of limitation statutes was stated as follows: ‘Our decisions seem uniformly to recognize that, although it does so result in some cases, it was never the purpose of the act to permit debtors to escape their obligations. Rather, the evil it sought to remedy “was to prevent demands originally invalid or which had been discharged from being enforced after such a lapse of time as would probably make it impossible for defendants to procure the evidence by which a just defense could be established.” ’ ””
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.