Railroad Commission of Ohio v. B a Worthington’s Empirical Analysis
225 U.S. 101 · 1912
Citation profile
36 federal appellate · 31 district · 81 state decisions
How this case has been cited
Cited by 265 later decisions (37 by the Supreme Court) — most recently October 2002 · most notably Simpson v. Shepard (1913), Stafford v. Wallace (1922)
36 federal appellate · 31 district · 81 state decisions — followed in 20 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.
Appellate journey
reviewedRailroad Commission v. Worthington (from Sixth Circuit Court of Appeals)
Relationships
Relies on Southern Pacific Terminal Company v. Interstate Commerce Commission · Coe v. Town of Errol · Standard Paint Company v. Trinidad Asphalt Manufacturing Company · Forsyth v. City of Hammond
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 265 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““By every fair test tlie transportation of this coal from the mine to the upper Late ports is an interstate carriage, intended by the parties to be such.””
4 later decisions quote this exact passage · from the majority““In those eases there was necessarily a local movement of freight, and it necessarily terminated at the seaboard. “But it was decided that its character and continuity as a movement in foreign commerce did not terminate, nor was it affected by being transported on local bills of lading. The principle enunciated in the cases were that it is the essential character of the commerce, not the accident of local or through bills of lading, which determines Federal or state control over it. And it takes character as interstate or foreign commerce when it is actually started in the course of transportation to another state or to a foreign country. The facts of the case at bar bring it within the ruling. The staves and logs were intended by the shippers to be exported to foreign countries, and th'ere was no interruption of their transportation to their destination except what was necessary for transshipment at New Orleans.””
1 later decision quote this exact passage · from the majority““It makes no difference, therefore, that the shipments of the products were not made on through bills of lading, or whether their initial point was Galveston or some other place in Texas. They were all destined for export, and by their delivery to the Galveston, Harrisburg & San Antonio Railway they must be considered as having been delivered to a carrier for transportation to their foreign destination; the tenminal company being a part of the railway for such purpose. The case therefore comes under Coe v. Errol, 116 U. S. 517 , 6 Sup. Ct. 475, 29 L. Ed. 715 , where it is said that goods are in interstate, and necessarily as well in foreign commerce, when they have ‘actually started in the course of transportation to another state or been delivered to a carrier for transportation.’ ””
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.