Burnett v. New York Central Railroad’s Empirical Analysis
1965
Citation profile
707 federal appellate · 185 district · 366 state decisions
How this case has been cited
Cited by 2,154 later decisions (67 by the Supreme Court) — most recently June 2025 · most notably United States v. Marion (1971), Wilson v. Garcia (1985)
707 federal appellate · 185 district · 366 state decisions — followed in 39 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
reviewedBurnett v. New York Central Railroad (from Sixth Circuit Court of Appeals)
Relationships
Applies 15 U.S.C. § 16 (§ 5 of the Clayton Antitrust Act of 1914) · 28 U.S.C. § 1406 · 45 U.S.C. § 51 (Federal Employers' Liability Act) · 45 U.S.C. § 56 (Federal Employers' Liability Act)
Relies on Rogers v. Missouri Pacific Railroad · Goldlawr, Inc. v. Heiman · Mondou v. New York, New Haven & Hartford Railroad · Order of Railroad Telegraphers v. Railway Express Agency, Inc.
Cited together with American Pipe & Construction Co. v. Utah · Order of Railroad Telegraphers v. Railway Express Agency, Inc. · Irwin v. Department of Veterans Affairs · Holmberg v. Armbrecht · Johnson v. Railway Express Agency, Inc.
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 2,154 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“promote justice by preventing surprises through the revival of claims that have been allowed to slumber until evidence has been lost, memories have faded, and witnesses have disappeared. The theory is that even if one has a just claim it is unjust not to put the adversary on notice to defend within the period of limitation and that the right to be free of stale claims in time comes to prevail over the right to prosecute them.”
107 later decisions quote this exact passage · from the majority“[p]etitioner here did not sleep on his rights but brought an action within the statutory period,”
14 later decisions quote this exact passage · from the majority“when a plaintiff begins a timely FELA action in a state court having jurisdiction, and serves the defendant with process and the plaintiff's case is dismissed for improper venue, the FELA limitation is tolled during the pendency of the state suit.”
9 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.