Illinois Central Railroad Company v. Joseph Behrens’s Empirical Analysis
233 U.S. 473 · 1914
Citation profile
89 federal appellate · 18 district · 296 state decisions
How this case has been cited
Cited by 474 later decisions (19 by the Supreme Court) — most recently November 2024 · most notably Rogers v. Missouri Pacific Railroad (1957), Circuit City Stores, Inc. v. Adams (2001)
89 federal appellate · 18 district · 296 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.
Appellate journey
reviewedthe decision below (from Fifth Circuit Court of Appeals)
Relationships
Relies on Mondou v. New York, New Haven & Hartford Railroad · Simpson v. Shepard · 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 474 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Every common carrier by railroad while engaging in commerce between any of the several States or Territories, . . . shall be liable in damages to any person suffering injury while he is employed by such carrier in such commerce. . . . (Next sentence from .1939 amendment) Any employee of a carrier, any part of whose duties as such employee shall be the furtherance of interstate or foreign commerce; or shall, in any way directly or closely and substantially, affect such commerce as above set forth shall, for the purposes of this Act, be considered as being employed by such carrier in such commerce and shall be considered as entitled to the benefits of this Act. ’ ’”
13 later decisions quote this exact passage · from the majority““Here, at the time of the fatal injury the intestate was engaged in moving several cars, all loaded with intrastate freight, from one part of the city to another. That was not a service in interstate commerce, and so the injury and resulting death were not within the statute. That he was expected, upon the completion of that task, to engage in another which would have been a part of interstate commerce, is immaterial under the statute, for by its terms the true test is the nature of the work being done at the time of the injury.””
12 later decisions quote this exact passage · from the majority““There can be no doubt that a right of recovery thereunder arises only where the injury is suffered while the carrier is engaged in interstate com merce and while the employé is employed by the carrier in such commerce. * * * The true test always 5s: Is the work in question a part of the interstate commerce in which the carrier is engaged?””
3 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.