Marine Engineers Beneficial Association v. Interlake Steamship Company’s Empirical Analysis
1962
Citation profile
148 federal appellate · 73 state decisions
How this case has been cited
Cited by 307 later decisions (26 by the Supreme Court) — most recently June 2023 · most notably Brotherhood of Railroad Trainmen v. Jacksonville Terminal Co. (1969), Volkswagenwerk Aktiengesellschaft v. Federal Maritime Commission (1968)
148 federal appellate · 73 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
Applies 29 U.S.C. § 152 (§ 2 of the National Labor Relations Act) · 29 U.S.C. § 158 (§ 8 of the National Labor Relations Act)
Relies on Universal Camera Corp. v. National Labor Relations Board · San Diego Building Trades Council v. Garmon · Leedom v. Kyne · Packard Motor Car Co. v. National Labor Relations Board · Local 761, International Union of Electrical, Radio & MacHine Workers v. National Labor Relations Board
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 307 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“so infinite and subtle that of necessity a large measure of informed discretion is involved in the exercise by the Board of its primary function to determine those who as a practical matter fall within the statutory definition of a 'supervisor.'”
6 later decisions quote this exact passage · from the dissent““When it is clear or may fairly be assumed that the activities which a State purports to regulate are protected by § 7 of the National Labor Relations Act, or constitute an unfair labor practice under § 8, due regard for the federal enactment requires that state jurisdiction must yield. * * * “At times it has not been clear whether the particular activity regulated by the States was governed by § 7 or § 8 or was, perhaps, outside both these sections. But courts are not primary tribunals to adjudicate such issues. It is essential to the administration of the Act that these determinations be left in the first instance to the National Labor Relations Board. What is outside the scope of this Court’s authority cannot remain within a State’s power and state jurisdiction too must yield to the exclusive primary competence of the Board. * * * In the absence of the Board’s clear determination that an activity is neither protected nor prohibited or of compelling precedent applied to essentially undisputed facts, it is not for this Court to decide whether such activities are subject to state jurisdiction.””
3 later decisions quote this exact passage · from the dissent“[W]e conclude that the task of determining what is a ‘labor organization’ in the context of § 8(b) must in any doubtful case begin with the National Labor Relations Board, and that the only workable way to assure this result is for the courts to concede that a union is a ‘labor organization’ for § 8(b) purposes whenever a reasonably arguable case is made to that effect.’”
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.