Primrose v. Western Union Telegraph Co.’s Empirical Analysis
154 U.S. 1 · 1894
Citation profile
51 federal appellate · 16 district · 143 state decisions
How this case has been cited
Cited by 262 later decisions (19 by the Supreme Court) — most recently June 2023 · most notably Adams Express Co. v. Croninger (1913), Kansas City Southern Railway Co. v. Carl (1913)
51 federal appellate · 16 district · 143 state decisions — followed in 32 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 Liverpool & Great Western Steam Co. v. Phenix Insurance · Hart v. Pennsylvania Railroad · Railroad Company v. Lockwood · The New Jersey Steam Navigation Company v. The Merchants' Bank of Boston · Howard v. Stillwell Bierce Manuf'G 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 262 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Where two parlies have made a contract which one of them has broken, the damages which the other party ought to receive in respect of such breach of contract should he such as may fairly and reasonably be considered either arising naturally; i. e., according to the usual course of things, from such breach of contract itself, or such as may reasonably be supposed to have been in the contemplation of both parties, at the time they made the contract, as the probable result of the breach.””
3 later decisions quote this exact passage · from the majority““6. The company will not be liable for damages or statutory penalties in any case where the claim is not presented in writing’ within sixty days after the message is filed with the company for transmission.””
2 later decisions quote this exact passage““Send the following message subject to the terms on back hereof, which are hereby agreed to.””
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.