Texas Co v. Brotherhood of Railway and Steamship Clerks’s Empirical Analysis
281 U.S. 548 · 1930
Citation profile
533 federal appellate · 64 district · 127 state decisions
How this case has been cited
Cited by 1,210 later decisions (198 by the Supreme Court) — most recently April 2024 · most notably Consolidated Edison Co of New York v. National Labor Relations Board (1938), Bell v. Hood (1946)
533 federal appellate · 64 district · 127 state decisions — followed in 24 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
reviewedTexas & N. O. R. v. Brotherhood of Railway & Steamship Clerks (from Fifth Circuit Court of Appeals)
Relationships
Relies on William Marbury v. James Madison · Mondou v. New York, New Haven & Hartford Railroad · Duplex Printing Press Co. v. Deering · The Daniel Ball
Cited together with Virginian Ry Co v. System Federation No 40 · Switchmen's Union of North America v. National Mediation Board · Elgin Ry Co v. Burley · General Committee of Adjustment of Brotherhood of Locomotive Engineers for Missouri-Kansas-Texas Rr v. Missouri-Kansas-Texas R Co · National Labor Relations Board v. Jones & Laughlin Steel Corp.
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 1,210 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'without interference, influence, or coercion'”
14 later decisions quote this exact passage · from the majority““The intent of Congress is clear with respect to the sort of conduct that is prohibited. ‘Interference’ with freedom of action and ‘coercion' refer to well understood concepts of the law. The moaning of the word ‘influence’ in this clause may be gathered from the context. Noscitur a sociis. Virginia v. Tennessee, 348 U.S. 503 , 519, 33 S.Ct. 728 , 37 L.Ed. 537 . The use of the word is not to be taken as interdicting' the normal relations and innocent communications which are a part of all friendly intercourse, albeit between employer and employee. ‘Influence’ in this context plainly means pressure, the use of the authority or power of either party to induce action by the other in derogation of what the statute calls ‘self-organizn tion. The phrase covers the abuse of relation or opportunity so as to corrupt or override the will, and it is no more difficult to appraise conduct of this sort in connection with the selection of representatives for the purposes of this Act than in relation to well-known applications of the law with respect to fraud, duress and undue influence.””
8 later decisions quote this exact passage · from the majority“All the proceedings looking to amicable adjustments and to agreements for arbitration of disputes, the entire policy of the Act, must depend for success on the uncoerced action of each party through its own representatives to the end that agreements satisfactory to both may be reached and the peace essential to the uninterrupted service of the instrumen-talities of interstate commerce may be maintained. There is no impairment of the voluntary character of arrangements for the adjustment of disputes in the imposition of a legal obligation not to interfere with the free choice of those who are to make such adjustments. On the contrary, it is of the essence of a voluntary scheme, if it is to accomplish its purpose, that this liberty should be safeguarded.”
6 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.