Green v. Chicago, Burlington & Quincy Railway Co.’s Empirical Analysis
205 U.S. 530 · 1907
Citation profile
210 federal appellate · 188 district · 258 state decisions
How this case has been cited
Cited by 979 later decisions (23 by the Supreme Court) — most recently May 2017 · most notably International Shoe Co. v. Washington (1945), Eastman Kodak Co of New York v. Southern Photo Materials Co (1927)
210 federal appellate · 188 district · 258 state decisions — followed in 35 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 St. Clair v. Cox · Ex parte Schollenberger · Lafayette Insurance v. French · Barrow Co v. Kane
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 979 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in substance nothing more than that of solicitation”
12 later decisions quote this exact passage · from the majority“* * * to constitute `doing business' the foreign corporation must have entered the state and engaged there in carrying on and transacting, through its agents, the ordinary business in which it is engaged, and the cases run with much unanimity to the effect that a foreign railroad corporation which has no tracks or railroad property within the state and operates none of its ordinary railroad business there is not doing business in the state in the sense that liability `to personal service is incurred' because it maintains an office and employs agents there to advertise its business and `solicit and procure passengers and freight to be transported over' its lines without the state.”
8 later decisions quote this exact passage · from the majority““The sole question for decision is whether, at the time of the service of the process, defendant was doing business within the district in such manner as to warrant the inference that it was present there. * * * The jurisdiction taken of foreign corporations, in the absence of statutory requirement or express consent, does not rest upon a fiction of constructive presence, like ‘qui facit per alium facit per se.’ It flows from the fact that the corporation itself does business in the state or district in such a manner and to such an extent that its actual presence there is established. That the defendant was not in New York, and hence was not found within the district, is clear.””
6 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.