St. Louis & San Francisco Railroad v. Conarty’s Empirical Analysis
238 U.S. 243 · 1915
Citation profile
84 federal appellate · 4 district · 64 state decisions
How this case has been cited
Cited by 189 later decisions (24 by the Supreme Court) — most recently January 2011 · most notably Urie v. Thompson (1949), Kernan v. American Dredging Co. (1958)
84 federal appellate · 4 district · 64 state decisions — followed in 20 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 Weeks v. United States · Michigan Central Railroad v. Vreeland · Reagan v. Farmers' Loan & Trust Co. · Pedersen v. Delaware, Lackawanna & Western Railroad · Martin Fairfax v. Hunter's
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 189 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The principal question in the case is whether, at the time he was injured, the deceased was within the class of persons for whose benefit the safety appliance acts required that the car be equipped with automatic couplers and drawbars of standard height; or, putting it in another way, whether his injury was within the evil against which the provision for such appliances are directed. It is not claimed, nor could it be, under the evidence, that the collision was proximately attributable to a violation of those provisions, but only that, had they been complied with, it would not have resulted in injury to the deceased. It therefore is necessary to consider with what purpose couplers and drawbars of the kind indicated are required, for where a duty is imposed for the protection of persons in particular situations or relations a breach of it which happens to result in injury to one in an altogether different situation or relation is not, as to him, actionable.”
5 later decisions quote this exact passage · from the majority““It is not claimed, nor could it be under the evidence, that the collision was proximately attributable to a violation of those provisions, but only that had they been complied with it would not have resulted in injury to the deceased. ... It is very plain that the evils against which these provisions are directed are those which attended the old-fashioned link and pin couplings where it was necessary for men to go between the ends of the cars to couple and uncouple them, and where the ears when coupled into a train sometimes separated by reason of the insecurity of the coupling. . . .We are of opinion that, the deceased, who was not endeavoring to couple or uncouple the ear or to handle it in any way, but was riding on, the colliding engine, was not in a situation where the absence of the prescribed coupler and drawbar operated as a breach of a duty imposed for his benefit, and that the Supreme Court of the State erred in concluding that the Safety Appliance Act required it to hold otherwise.””
3 later decisions quote this exact passage · from the majority“It shall be unlawful for any common carrier engaged in interstate commerce by railroad to haul or permit to be hauled or used on its line any car used in moving interstate traffic not equipped with couplers coupling automatically by impact, and which can be uncoupled without the necessity of men going between the ends of the cars.”
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.