45 U.S.C. § 181
Section 181 · Application of subchapter I to carriers by air
Amended 2 times on record
Applied in 260 court decisions — leading case Republic Steel Corp. v. Maddox (1965)
Most recently applied in Bryan v. American Airlines, Inc. (February 2021)
Applied most in the District Circuit Circuit (25 decisions)
Cases citing this section usually also cite 45 U.S.C. § 151 · 45 U.S.C. § 152 · 45 U.S.C. § 153
How often courts cite this section
Court decisions citing this, by year.Markers show enactment, consequential amendments, and circuit splits over this section — watch for a citation surge after a change or a disagreement. The dip in the last several years is a data-coverage gap, not a real trend — our corpus holds fewer opinions from the most recent years, so recent citations are undercounted.
All of the provisions of subchapter I of this chapter except section 153 of this title are extended to and shall cover every common carrier by air engaged in interstate or foreign commerce, and every carrier by air transporting mail for or under contract with the United States Government, and every air pilot or other person who performs any work as an employee or subordinate official of such carrier or carriers, subject to its or their continuing authority to supervise and direct the manner of rendition of his service.