Brotherhood of Railroad Trainmen Enterprise Lodge No 27 v. Toledo P & Wrr’s Empirical Analysis
321 U.S. 50 · 1944
Citation profile
221 federal appellate · 36 district · 43 state decisions
How this case has been cited
Cited by 526 later decisions (32 by the Supreme Court) — most recently June 2026 · most notably United States v. United Mine Workers of America (1947), Boys Markets, Inc. v. Retail Clerks Union, Local 770 (1970)
221 federal appellate · 36 district · 43 state decisions — followed in 10 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
reviewedToledo, P. & W. R. R. v. Brotherhood of Railroad Trainmen (from Seventh Circuit Court of Appeals)
Relationships
Relies on Gully v. First Nat. Bank in Meridian · Virginian Ry Co v. System Federation No 40 · Cohens v. Virginia · In re Debs · Texas Co v. Brotherhood of Railway and Steamship Clerks
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 526 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“No restraining order or injunctive relief shall be granted to any complainant who has failed to comply with any obligation imposed by law which is involved in the labor dispute in question, or who has failed to make every reasonable effort to settle such dispute either by negotiation or with the aid of any available governmental machinery of mediation or voluntary arbitration.”
20 later decisions quote this exact passage · from the majority““Representative O’Connor, supporting the sponsor’s view, characterized section 8 as ‘the “clean hands” provision’ and said: “ ‘That section provides that a complainant shall not be entitled to an injunction if he has not complied with any contract or obligation on his part or has not made every reasonable effort to settle the dis pute by the available methods of arbitration or mediation. Surely, this fundamental principle of equity that “he who seeks justice must do justice” should apply in labor disputes as well as in other judicial controversies.’ ””
3 later decisions quote this exact passage · from the majority“if it refuses, it loses the legal right to have an injunction issued by a federal court”
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.