North Carolina Railroad Company v. James a Zachary’s Empirical Analysis
232 U.S. 248 · 1914
Citation profile
122 federal appellate · 15 district · 292 state decisions
How this case has been cited
Cited by 544 later decisions (35 by the Supreme Court) — most recently July 2024 · most notably Whitney v. People of State of California (1927), Central Vermont Railway Company v. Mary Theresa White L (1915)
122 federal appellate · 15 district · 292 state decisions — followed in 41 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 Mondou v. New York, New Haven & Hartford Railroad · Michigan Central Railroad v. Vreeland · Pedersen v. Delaware, Lackawanna & Western Railroad · Johnson v. Southern Pacific 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 544 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Again, it is said that, because deceased had left his engine and. was going to his boarding house, he was engaged upon a personal errand, and not upon the carrier’s business. Assuming (what is not clear) that the evidence fairly tended to indicate the boarding house as his destination, it nevertheless also appears that deceased was shortly to depart upon his run, having just pre pared Ms engine for the purpose, and that he had not gone beyond the limits of the railroad yard when he was struck. There is nothing to indicate that this brief visit to the hoarding house was at all out of the ordinary, or was inconsistent with Ms duty to his employer. It seems to us clear that the man was still 'on duty,’ and employed in commerce, notwithstanding his temporary absence from the locomotive engine.””
7 later decisions quote this exact passage · from the majority““It is argued that because, so far as appears, deceased had not previously participated in any movement of interstate freight, and the through cars had not as yet been attached to his engine, his employment in interstate commerce was still in futuro. It seems to us, however, that his acts in inspecting, oiling, firing, and preparing his engine for the trip to Selma were acts performed as a part of interstate commerce, and the circumstance that the interstate freight cars had not as yet been coupled up is legally insignificant.””
4 later decisions quote this exact passage · from the majority“employed by such carrier in such commerce.”
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.