Woodrum v. Donovan’s Empirical Analysis
1983
Citation profile
How this case has been cited
Cited by 70 later decisions — most recently May 2011 · most notably Woodrum v. United States (1984), 570 F. Supp. 41 - Abbott v. Donovan (1983)
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 19 U.S.C. § 2102 · 19 U.S.C. § 2272 · 19 U.S.C. § 2320 · 19 U.S.C. § 2395 · 29 U.S.C. § 158 (§ 8 of the National Labor Relations Act) · 29 U.S.C. § 203
Relies on Dandridge v. Williams · Eisenstadt v. Baird · Lindsley v. Natural Carbonic Gas Co. · Federal Election Commission v. Democratic Senatorial Campaign Committee · Lindsey v. Normet
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 70 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) that a significant number or proportion of the workers in such workers’ firm or an appropriate subdivision of the firm have become totally or partially separated, or are threatened to become totally or partially separated, (2) that sales or production, or both, of such firm or subdivision have decreased absolutely, and (3) that increases of imports of articles like or directly competitive with articles produced by such workers’ firm or an appropriate subdivision thereof contributed importantly to such total or partial separation, or threat thereof, and to such decline in sales or production.”
24 later decisions quote this exact passage“The repair and maintenance of a ship is clearly a service to an existing commodity. Even if the repair necessitates the use of new materials, it cannot be said to be the creation of a new ship any more than overhauling an automobile can be said to be manufacturing a car. * * * Fortin * * * leaves no doubt that services do not fall within the terms of § 2272. * * * Appellants contend that Fortin is distinguishable because in that case nothing tangible was produced. In our situation, the service did involve a tangible item — a ship — but the same item was also the end product. There was no transformation, but a mere refurbishing of what already existed. [Emphasis in original.] [Footnote omitted.]”
2 later decisions quote this exact passage“* * * It is clear that production under section 222(3) requires the manufacture or creation of something tangible. The Pemberton test is whether the workers in question transformed articles into new and different articles. It is difficult to quarrel with the reasoning of Pemberton for it cannot be questioned that “produce” means to give birth, create or bring into existence. There is no doubt that plaintiffs’ work was performed on tangible articles, Chrysler cars. By their own admission, however, plaintiffs did not manufacture new articles. Rather, their work consisted of adjustments and preparation of the tangible article which was also the end product. As in Pemberton , plaintiffs Woodrum, Johnson and Dorsey merely made repairs and serviced already completed articles. There is no evidence which indicates that plaintiffs made substantial changes to the new Chrysler cars resulting in their transformation into a new end product. * * *”
1 later decision quote this exact passage
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.