Gila Valley Globe Northern Railway Company v. John Hall’s Empirical Analysis
232 U.S. 94 · 1914
Citation profile
152 federal appellate · 5 district · 208 state decisions
How this case has been cited
Cited by 424 later decisions (34 by the Supreme Court) — most recently August 2009 · most notably Dimick v. Schiedt (1935), Seaboard Air Line Railway v. Horton (1914)
152 federal appellate · 5 district · 208 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 Inland & Seaboard Coasting Co. v. Tolson · Choctaw, Oklahoma & Gulf R. R. v. McDade · Randall v. Baltimore O R · Northern Pacific Railroad v. Herbert
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 424 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““An employee assumes the risk of dangers normally incident to the occupation in which he voluntarily engages, so far as these are not attributable to the employer’s negligence. But the employee has a right to assume that his employer has exercised proper care with respect to providing a safe place of work, and suitable and safe appliances for the work, and is not to be treated as assuming the risk arising from a defect that is attributable to the employer’s negligence, until the employee becomes aware of such defect, or unless it is so plainly observable that he may be presumed to have known of it. Moreover, in order to charge an employee with the assumption of a risk attributable to a defect due to the employer’s negligence, it must appear not only that he knew (or is presumed to have known) of the defect, but that he knew it endangered his safety; or else such danger must have been so obvious that an ordinarily prudent person, under the circumstances, would have appreciated it.””
16 later decisions quote this exact passage · from the majority““And 'then, the question whether the defect was such as to render the use of the car dangerous was in dispute at the trial; hence, it could not he properly held that the risk was indisputably obvious, even to one who knew of the defect. It is quite clear, therefore, that a verdict could not properly have been directed in iavor of the defendant upon the ground that the plaintiff, in using the car, had assumed an obvious risk.””
2 later decisions quote this exact passage · from the majority““The constitutional question involved was re-examined in Arkansas Cattle Co. v. Mann, 130 U. S. 69, 73 [ 9 S. Ct. 458 , 32 L. ed. 854] and the decision in the Herbert case was adhered to, it being held that the practice under criticism did not in any just sense impair the right of trial by jury.””
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.