Northern Pacific Railway Company v. State of North Dakota’s Empirical Analysis
Citation profile
1 federal appellate · 12 district · 71 state decisions
How this case has been cited
Cited by 106 later decisions (3 by the Supreme Court) — most recently February 2000 · most notably New York v. United States (1947), Northern Pacific Railway Co. v. Department of Public Works (1925)
1 federal appellate · 12 district · 71 state decisions — followed in 30 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 Smyth v. Ames · Simpson v. Shepard · Reagan v. Farmers' Loan & Trust Co. · Interstate Commerce Commission v. Union Pacific Railroad · Chicago Ry Co v. Wellman
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 106 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Broad as is the power of regulation, the State does not enjoy the freedom of an owner. The fact that the [utility's] property is devoted to a public use on certain terms does not justify the requirement that it shall be devoted to other public purposes, or to the same use on other terms, or the imposition of restrictions that are not reasonably concerned with the proper conduct of the business according to the undertaking which the [utility] has expressly or impliedly assumed.”
2 later decisions quote this exact passage · from the majority““Frequently, attacks upon state rates have raised the question as to the profitableness of the entire intrastate business under the state’s requirements. But the decisions in this class of cases (which we have cited in the margin) furnish no ground for saying that the state may set apart a commodity or a special class of traffic and impose upon it any rate it pleases, provided only that the return from the entire intrastate business is adequate.” (p. 599.)”
1 later decision quote this exact passage · from the majority“But a different question arises when the State has segregated a commodity, or a class of traffic, and has attempted to compel the carrier to transport it at a loss or without substantial compensation even though the entire traffic to which the rate is applied is taken into account. On that fact being satisfactorily established, the presumption of reasonableness is rebutted. * * *”
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.