Matthews v. Southern Ry. System’s Empirical Analysis
157 F.2d 609 · 1946
Citation profile
7 federal appellate · 2 district · 1 state decisions
How this case has been cited
Cited by 16 later decisions — most recently March 2018
7 federal appellate · 2 district · 1 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
Relies on Morgan v. Commonwealth of Virginia · New Jersey Steamboat Co. v. Brockett · Texas Midland Railroad v. Dean · Gillingham v. Ohio River Railroad · Duggan v. Baltimore & Ohio Railroad
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““This case is governed by the rules of law applicable to the obligations of a common carrier to its passengers and its liabilities for breach of those obligations. A common carrier is required to protect its passengers against assault or interference with the peaceful completion of their journey. But an exception to the general rule is that an agent of the carrier is not required to interfere with a known officer of the law apparently engaged in the performance of his duty. This exception covers the action of an agent of a carrier in pointing out to a known officer of the law persons as to whom the officer inquires. * * * Under the exception, the railroad is not liable for action of its agents in notifying police officers of violations of law or suspected violations. This latter is so because of the basic public policy which protects such notification generally and also because of the primary duty of the conductor of a train to protect passengers from injury by others; e. g., assault, robbery, insult, disturbance, etc., in which cases the conductor must call the police. But the exception goes no further. It does not cover the action of the agent in otherwise causing, procuring, assisting in, or participating in the arrest or ejection, or where the arrest is at the instance of the agent. In other words, there is a clear line between the action of an agent of a carrier in merely notifying the police of a violation of law or identifying persons at the request of a police officer”
3 later decisions quote this exact passage · from the dissent
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.