Washington Co v. Hickey’s Empirical Analysis
166 U.S. 521 · 1897
Citation profile
113 federal appellate · 3 district · 56 state decisions
How this case has been cited
Cited by 224 later decisions (11 by the Supreme Court) — most recently August 2013 · most notably Berger v. United States (1935), Edmonds v. Compagnie Generale Transatlantique (1979)
113 federal appellate · 3 district · 56 state decisions — followed in 18 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.
Appellate journey
reviewedthe decision below (from District of Columbia Circuit Court of Appeals)
Relationships
Relies on Scheefer v. Railroad Company · Nash v. Towne · Insurance Company v. Tweed · Carter v. Towne
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 224 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'was not of a character which could have misled the defendant at the trial'”
4 later decisions quote this exact passage · from the majority“The act of the driver being a negligent act, and that act being in full force and in the very process of execution at the time the accident occurred, which accident would not have happened but for such negligent act, the fact that another negligent act of a third party contributed to the happening of the accident would not absolve the Horse Car Company. The negligent act of the horse car driver joined with and became a part of the other act in wrongfully lowering the gates, as described, and both acts constituted but one cause for the commotion which naturally resulted therefrom, and on account of both of these acts, as parts of a whole transaction, the injury occurred.”
2 later decisions quote this exact passage · from the majority““The two so-called negligent acts were In fact united in producing the result, and they made one cause of concurring negligence on the part of both companies. They were in point of time substantially simultaneous acts and parts of one whole transaction, and it would be improper to attempt a separation in the manner asked for by the counsel for the horse car company.””
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.