Adams Express Co. v. Croninger’s Empirical Analysis
226 U.S. 491 · 1913
Citation profile
331 federal appellate · 154 district · 792 state decisions
How this case has been cited
Cited by 1,837 later decisions (79 by the Supreme Court) — most recently May 2025 · most notably Parker v. Brown (1943), Southern Pacific Co. v. Jensen (1917)
331 federal appellate · 154 district · 792 state decisions — followed in 48 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 Texas Pacific Railway Company v. Abilene Cotton Oil Company · Mondou v. New York, New Haven & Hartford Railroad · Armour Packing Company v. United States · Louisville & Nashville Railroad v. Mottley
Cited together with New York Nh Hartford Co v. Nothnagle · Georgia Florida Alabama Railway Company v. Blish Milling Company · Kansas City Southern Railway Co. v. Carl · Hart v. Pennsylvania Railroad · Missouri Pacific Railroad v. Elmore & Stahl
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 1,837 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[The Carmack Amendment] embraces the subject of the liability of the carrier under a bill of lading which he must issue, and limits his power to exempt himself by rule, regulation, or contract. Almost every detail of the subject is covered so completely that there can be no rational doubt but that Congress intended to take possession of the subject, and supersede all state regulation with reference to it.”
58 later decisions quote this exact passage · from the majority“loss, damage or injury to such property.”
36 later decisions quote this exact passage · from the majority“[S]o long as the limitation of liability was the result of a “fair, open, just and reasonable agreement” between carrier and shipper, entered into by the shipper “for the purpose of obtaining the lower of two or more rates of charges proportioned to the amount of risk,” ... and the shipper was given “the option of higher recovery upon paying a higher rate,” ... the agreement was enforceable at common law.”
12 later decisions 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.