Northern Pacific Railway Co. v. Washington ex rel. Atkinson’s Empirical Analysis
222 U.S. 370 · 1912
Citation profile
40 federal appellate · 36 district · 115 state decisions
How this case has been cited
Cited by 318 later decisions (42 by the Supreme Court) — most recently May 2001 · most notably Mondou v. New York, New Haven & Hartford Railroad (1912), Adams Express Co. v. Croninger (1913)
40 federal appellate · 36 district · 115 state decisions — followed in 27 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 Southern Railway Company v. United States · Smith v. State of Alabama · Sherlock v. Alling · Ed Reid v. People of the State of Colorado · Escanaba Lake Michigan Transp Co v. City of Chicago
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 318 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is elementary, and such is the doctrine announced by the cases to which the court below referred, that the right of a state to apply its police power for the purpose of regulating interstate commerce, in a case like this, exists only from the silence of Congress on the subject, and ceases when Congress acts on the subject or manifests its purpose to call into play its exclusive power.””
2 later decisions quote this exact passage · from the majority““ * * * We are of opinion -that it becomes manifest that it would cause the statute to destroy itself to give to the clause postponing its operation for one year the meaning which must be affixed to it in order to hold that during the year Of postponement state police laws applied. In the first place, no conceivable reason has been, or we think can be, suggested for the postponing provision if it was contemplated that the prohibitions of state laws should apply in the meantime. This is true because if it be that it was contemplated that the subject dealt with should be controlled during the year by state laws, the postponement of the prohibitions of the act could accomplish no possible purpose. This is well illustrated by this ease, where, by the ruling below, a state regulation substantially similar to that contained in the act of Congress is made applicable. In the second place, the obvious suggestion is that the purpose of Congress in giving time was to enable the necessary adjustments to be made by the railroads to meet the new conditions created by the act, a purpose which would of course be frustrated by giving to the provision as to postponement a significance which would destroy th'e very reason which caused it to be enacted.””
1 later decision quote this exact passage · from the majority“* * * as the enactment by Congress of the law in question was an assertion of its power, by the fact alone of such manifestation that subject was at once removed from the sphere of the operation of the authority of the state.”
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.