United States of America v. Lehigh Valley Railroad Company’s Empirical Analysis
220 U.S. 257 · 1911
Citation profile
87 federal appellate · 31 district · 47 state decisions
How this case has been cited
Cited by 257 later decisions (38 by the Supreme Court) — most recently January 2013 · most notably New Colonial Ice Co. v. Helvering (1934), United States v. Aluminum Co. of America (1945)
87 federal appellate · 31 district · 47 state decisions — followed in 14 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 Northern Securities Company v. United States · United States ex rel. Attorney General of the United States v. Delaware & Hudson Co. · New York New Haven Hartford Railroad Company v. Interstate Commerce Commission · Chapman v. Barney · Pullman's Co v. Central Transp Co
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 257 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““While that decision expressly held that stock ownership by a railroad company in a bona fide corporation, irrespective of the extent of such ownership, did not preclude a railroad company from transporting the commodities manufactured, mined, produced, or owned by such corporation, nothing in. that conclusion foreclosed the right of the government to question the power of, a railroad company to transport in interstate commerce a commodity' manufactured, mined, owned, or produced by a corporation in which the railroad held stock and where the power of the railroad company as a stockholder was used to obliterate all distinctions between the two corporations; that is to say, where the power was exerted in such a manner as to so commingle the affairs of both as by necessary effect to make such affairs practically indistinguishable and therefore to cause both corporations to be one for all purposes. To what extent the amendment charged this to be the case will become manifest by again particularly considering its averments concerning the use by the railroad company of the coal company as a purchaser of coal, as also the direct charge made in the proposed amendment ihat by such acts the railroad company was enabled to control all or a greater portion of the coal produced in the region tributary to its road, and thus to dominate the situation and fix the price, not only at which all the coal could be bought, but at which it could be sold at the seaboard for consumption. “That the f”
2 later decisions quote this exact passage · from the majority““In substance it was averred that as to this particular coal company the railroad company was not only the owner of all the stock issued by the coal company, but that the railroad company so used the power thus resulting from its stock ownership as to deprive the coal company of all real independent existence, and to make it virtually but an agency or dependency or department of the railroad company. In other words, in great detail facts-were averred which tended to establish that there was no distinction in practice between the coal company and the railroad company, the latter using the coal company as a mere device to enable the railroad company to violate the provisions of the commodities clause. It was expressly charged that in consequence of these facts: “ ‘The coal company is not a bona fidfe mining company, but is merely an adjunct or instrumentality of the defendant. The defendant is in legal effect the owner of and hap a pecuniary interest in the coal mined by the coal company, and which is transported by the defendant.’ “Not only was it thus charged that the railroad company used its stock ownership to so commingle the operations of the affairs of the mining company with its own as to render it impossible to distinguish as a matter of fact between them, but it was moreover expressly in substance charged that, exerting its influence as the owner of all the stock of the coal company, the railroad company caused the coal company to buy up all the coal produced by other”
1 later decision quote this exact passage · from the majority““The prohibitions oí the statute were addressed only to a legal or equitable interest in the commodities to which the prohibitions referred; that they therefore did not prohibit a railroad company from transporting commodities mined, manufactured, produced, or owned by a distinct corporation, merely because the railroad company was the owner of some or all of the stock in such corporation.””
1 later decision 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.