Adams Express Company v. Commonwealth of Kentucky’s Empirical Analysis
206 U.S. 129 · 1907
Citation profile
3 federal appellate · 3 district · 27 state decisions
How this case has been cited
Cited by 57 later decisions (8 by the Supreme Court) — most recently February 1947 · most notably United States of America v. American Tobacco Co. (1911), Carter v. Commonwealth of Virginia Dickerson (1944)
3 federal appellate · 3 district · 27 state decisions — followed in 10 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 Connolly v. Union Sewer Pipe Co. · United States v. Reese · Leisy v. Hardin · United States v. Ju Toy · United States v. Steffens
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 57 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““As the general principle is that goods moving in interstate commerce cease to bé such commerce only after delivery and sale in the original package, and as the settled rule is that the Wilson law was not an abdication of the power of Congress to regulate interstate commerce, since that law simply affects an incident of such commerce by allowing the state power to attach after delivery and before sale, we are not concerned with whether, under the law of any particular state, the liability of a railroad company as carrier ceases and becomes that of a warehouseman on the goods reaching their ultimate destination before notice and before the expiration of a reasonable time for the consignee to receive the goods from the carrier. For, whatever may be the divergent legal rules in the several states concerning the precise time when the liability of a carrier as such in respect to the carriage of goods ends, they cannot affect the general principle as to when an interstate shipment ceases to be under the protection of the commerce clause of the Constitution, and thereby comes under the cbntrol of the state authority.””
1 later decision quote this exact passage · from the majority““The said Joe Newland and the Adams Express Company, the latter being a partnership engaged in and carrying on the business of a common carrier of packages, goods, wares, and merchandise, by the method known as express, * * did in Laurel comity, Kentucky, on the seventeenth day of February, 1901. unlawfully and willfully carry for and deliver to George Meece a parcel, package shipment, and quantity of intoxicating, spirituous, vinous and malt liquors * * * to be and which, was paid for on delivery to East Bern-stndt, in said Laurel county, same being at the timo a shipment commonly known and called C. O. 11. shipments, ® * * said shipment and delivery being made and done at the time by said .Toe Newland and said Adams Express Company in the usual course of business of said Adams Express Company.””
1 later decision quote this exact passage““A statute of Kentucky, making penal all shipments of liquor ‘to he paid for on delivery, commonly called O. O. D. shipments,’ and further providing that the place where the money is paid or the goods delivered shall be deemed to be the place of sale, and that the carrier and his agent delivering the goods shall be jointly liable with the vendor, is as applied to shipment from one state to another an attempt to regulate interstate commerce, and beyond the power of the state.””
1 later decision quote this exact passage
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.