Great Northern Railway Company v. Gertrude O'Connor’s Empirical Analysis
232 U.S. 508 · 1914
Citation profile
36 federal appellate · 12 district · 103 state decisions
How this case has been cited
Cited by 224 later decisions (12 by the Supreme Court) — most recently August 2012 · most notably Norfolk Southern Railway Co. v. James N. Kirby, Pty Ltd. (2004), Boston & Maine Railroad v. Hooker (1914)
36 federal appellate · 12 district · 103 state decisions — followed in 28 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 Adams Express Co. v. Croninger · Hart v. Pennsylvania Railroad · Kansas City Southern Railway Co. v. Carl · Missouri Kansas Texas Railway Company v. Harriman Brothers · Interstate Commerce Commission v. Delaware, Lackawanna & Western Railroad
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 224 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he transfer company had been intrusted with goods to be shipped by railway, and, nothing to the contrary appearing, the carrier had the right to assume that the transfer company could agree upon the terms of shipment, some of which were embodied in the tariff. The carrier was not bound by [plaintiff’s] private instructions or limitation on the authority of the transfer company, whether it be treated as agent or forwarder.”
5 later decisions quote this exact passage““If no value is stated, the tariff rate applicable to such a state of facts applies. If, on the other hand, there are -alternative rates based on value, and the shipper names a value to secure the lower rate, the carrier, in the absence of something to show rebating or false billing, is entitled to collect the rate which applies to goods of that class, and, if sued for their loss, it is liable only for the loss of which shipper has declared them to be in class and value.” Great Northern Railroad v. O’Conner, 232 U. S. 508 , 34 Sup. Ct. 380, 58 L. Ed. 703 .”
1 later decision quote this exact passage · from the majority““But so long as the tariff rate, based oh value, remained operative, it was binding upon the shipper and carrier alike, and was to be enforced by the courts in fixing the rights and liabilities of the parties. The tariffs are filed with the commission and are open to-inspection at every station.””
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.