Wabash Railroad v. Hayes’s Empirical Analysis
234 U.S. 86 · 1914
Citation profile
22 federal appellate · 4 district · 93 state decisions
How this case has been cited
Cited by 162 later decisions (11 by the Supreme Court) — most recently March 2021 · most notably Baltimore Co v. Phillips (1927), Magnolia Petroleum Co. v. Hunt (1943)
22 federal appellate · 4 district · 93 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 Mondou v. New York, New Haven & Hartford Railroad · Seaboard Air Line Railway v. Horton · North Carolina Railroad Company v. James a Zachary · Chambers v. Baltimore & Ohio Railroad · Illinois Central Railroad Company v. Joseph Behrens
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 162 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[h]ad the injury occurred in interstate commerce, as was alleged, the Federal Act undoubtedly would have been controlling, and a recovery could not have been had under the common or statute law of the state; in other words, the Federal act would have been exclusive in its operation, not merely cumulative.... On the other hand, if the injury occurred outside of interstate commerce, the Federal act was without application, and the law of the state was controlling.”
3 later decisions quote this exact passage · from the majority“' “Where the state court treats a mistaken allegation that the injury occurred in interstate commerce as eliminated, it merely gives effect to a rule of local practice and does not deprive defendant of any federal right. Quaere, as to what the effect would be if the shift from a claim under the federal act to one .under the state law cut the.defendant •off from presenting a defense open under the latter or deprived him of a right of removal.””
2 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.