Newport News & M. Val. Co. v. United States’s Empirical Analysis
61 F. 488 · 1894
Citation profile
8 federal appellate · 3 district ·
How this case has been cited
Cited by 14 later decisions (1 by the Supreme Court) — most recently February 1941
8 federal appellate · 3 district ·
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
Relies on Weeks v. Wilson Transit 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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“‘'Congress did not mean tliat, simply because the carrier had encountered a storm, therefore he should be excused. It must appear that the storm ‘prevented’ obedience. The storm could not be prevented. Its consequences may be avoided or mitigated by the exercise of diligence. If, with all reasonable exertion, a carrier is unable, by reason of a storm, to comply with the law, then he has been unavoidably ‘prevented’ from obeying the law. If, notwithstanding the storm,. he could by due care have complied with the law, then he is at fault, because ‘his own negligence is the last link in the chain of cause and effect, and in law the proximate cause’ of the failure to comply with the law. Therefore, to avail himself of the excuse of ‘storm,’ the carrier must show, not only the fact of a storm, but that with due care lie was ‘prevented,’ as an unavoidable result of the storm, from complying with the law. We can reach but one conclusion as to the meaning of Congress by the expression ‘other accidental causes.’ If the storm is no excuse, unless its unavoidable effect was to prevent compliance, then it follows that no other accidental cause would be an excuse, unless that cause and its effect are likewise unavoidable. The meaning of the general words, ‘other accidental causes,’ must be ascertained by referring to the preceding special words. The rule ‘noscitur a sociis’ is clearly applicable. A storm is unavoidable, in the sense that it cannot be prevented. ‘Other accidental causes’ m”
4 later decisions quote this exact passage · from the majority““That if they found that the live stock had been confined in the cars of the defendant company for a longer period than 28 consecutive hours without unloading for rest, food, and water it would be no defense that such confinement had been caused by an accident to the train due to the negligence of defendant.””
1 later decision 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.