Atchison Topeka Santa Fe Railway Company v. Samuel Calhoun’s Empirical Analysis
213 U.S. 1 · 1909
Citation profile
75 federal appellate · 3 district · 131 state decisions
How this case has been cited
Cited by 236 later decisions (1 by the Supreme Court) — most recently June 2021 · most notably Republic of France v. French Overseas Corporation the Malcolm Baxter Jr (1928), Grand Trunk Western Railway Company v. George Lindsay (1914)
75 federal appellate · 3 district · 131 state decisions — followed in 26 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 Milwaukee and Saint Paul Railway Company v. Kellogg · Railroad Company v. Stout · Union Pac Ry Co v. McDonald · Washington Co v. Hickey
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 236 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Where, in the sequence of events between the original default and the final mischief an entirely independent and unrelated cause intervenes, and is of itself sufficient to stand as the cause of the mischief, the second cause is ordinarily regarded as the proximate cause and the other as the remote cause." Atchison, T. & S.F.R. Co. v. Calhoun, 213 U.S. 1 , 29 S.Ct. 321, 323 , 53 L.Ed. 671 .”
13 later decisions quote this exact passage · from the majoritye.g. The Santa Rita · Jennings v. Davis“"* * * [o]ne is held responsible for all the consequences of his act which are natural and probable, and ought to have been foreseen by a reasonably prudent man." * * * * * * "But even where the highest degree of care is demanded, still the one from whom it is due is bound to guard only against those occurrences which can reasonably be anticipated by the utmost foresight. It has been well said that `if men went about to guard themselves against every risk to themselves or others which might by ingenious conjecture be conceived as possible, human affairs could not be carried on at all. The reasonable man, then, to whose ideal behavior we are to look as the standard of duty, will neither neglect what he can forecast as probable, nor waste his anxiety on events that are barely possible. He will order his precaution by the measure of what appears likely in the known course of things.' Pollock on Torts (8th ed.) 41."”
6 later decisions quote this exact passage · from the majoritye.g. Gresham v. Courson · Smith v. Sharp
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.