Ward v. Atlantic Coast Line Railroad’s Empirical Analysis
1960
Citation profile
126 federal appellate · 11 district · 45 state decisions
How this case has been cited
Cited by 244 later decisions (10 by the Supreme Court) — most recently October 2024 · most notably Houston v. Lack (1988), Community for Creative Non-Violence v. Reid (1989)
126 federal appellate · 11 district · 45 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
reviewedWard v. Atlantic Coast Line Railroad (from Fifth Circuit Court of Appeals)
Relationships
Relies on Rogers v. Missouri Pacific Railroad · Ferguson v. Moore-McCormack Lines, Inc. · Sinkler v. Missouri Pacific Railroad · Baker v. Texas and Pacific Railway Co
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 244 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““If you find that the railroad, * * had the power to direct, control and supervise the plaintiff in the performance of the work he was doing at the time he was injured, then you should find that the plaintiff was employed by the defendant railroad at the time he was injured.””
6 later decisions quote this exact passage · from the dissent“In the present case the respondent, rather than doing the necessary switching incident to its business in the Houston Terminal area, arranged that the Belt Railway should supply the crews and equipment to perform this operation on its behalf. But the evidence clearly establishes that the respondent's trains, when under the control of the Belt Railway's switching crews, were being handled to further the task of the respondent's enterprise. While engaged in switching and handling respondent's cars and trains about the terminal area, the Belt Railway employees on the job were, for purposes of the FELA, as much a part of the respondent's total enterprise as was the petitioner while engaged in his regular work on the respondent's car. 10 "It is manifest that the corporate autonomy of the Belt Railway, and its freedom from detailed supervision of its operations by respondent are irrelevant inasmuch as the switching crew of the Belt Railway Company at the moment of the collision in the station was engaged in furthering the operational activities of respondent. We therefore hold that when a railroad employee's injury is caused in whole or in part by the fault of others performing, under contract, operational activities of his employer, such others are `agents' of the employer within the meaning of § 1 of FELA.”
4 later decisions quote this exact passage · from the majority“neither the railroad's communication of its concept of petitioner's status to petitioner, nor his acquiecence therein, if shown, is determinative of the issue. The parties' characterization is but one factor to be considered among others”
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.