American Railroad Company of Porto Rico v. Federico Didricksen’s Empirical Analysis
227 U.S. 145 · 1913
Citation profile
58 federal appellate · 9 district · 129 state decisions
How this case has been cited
Cited by 256 later decisions (15 by the Supreme Court) — most recently June 2019 · most notably Chesapeake Ohio Railway Company v. Addie Kelly (1916), St. Louis, Iron Mountain & Southern Railway Co. v. Craft (1915)
58 federal appellate · 9 district · 129 state decisions — followed in 32 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 Michigan Central Railroad v. Vreeland · Harriman v. Interstate Commerce Commission · Isabella Gonzales v. William Williams · American Railroad Company of Porto Rico v. Ann Elizabeth Birch
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 256 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But the act, in case of the death of such an employee from his injury, creates a new and distinct right of action for the benefit of the dependent relatives named in the statute. The damages recoverable are limited to such loss as results to them because they have been deprived of a reasonable expectation of pecuniary benefits by the wrongful death of the injured employe> 1 17 Also, in the early case of Cain v. Southern Railway Company, 199 F. 211 (C.C.E.D.Tenn., 1911), it was held that recovery of damages under the Act of 1908 is limited to the "* * * pecuniary injury or loss sustained by the beneficiaries from the death of the deceased * * *”
8 later decisions quote this exact passage · from the majority““It is not easy to see how effect can be given to the Employers’ liability Act of 1908 in Porto Rico, without concluding that this act of 1903 [Safety Appliance Act] is also in force there, since the former, as pointed out in the Birch Case, 224 U. S. 547 , 555, provides in its third section ‘that no employee who may be injured or killed shall be held to have- been guilty of contributory negligence in any case where the violation by such common carrier of any statute enacted for the safety of employees contributed to the injury or death.’ The fourth section contains a like provision concerning assumption of risk.””
1 later decision quote this exact passage · from the majority“organization (of Puerto Rico) is in most essentials that of those political entities known as Territories”
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.