Choate v. Louisville and Nashville Railroad Company’s Empirical Analysis
715 F.2d 369 · 1983
Citation profile
19 federal appellate · 2 district · 3 state decisions
How this case has been cited
Cited by 38 later decisions — most recently March 2004 · most notably Beard v. Carrollton Railroad (1989), Truex v. Garrett Freightlines, Inc. (1985)
19 federal appellate · 2 district · 3 state decisions
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 Farmer v. United Brotherhood of Carpenters & Joiners of America, Local 25 · Andrews v. Louisville & Nashville Railroad · 2 Cal. 3d 493 - Alcorn v. Anbro Engineering, Inc. · 66 Ill. 2d 85 - Public Finance Corp. v. Davis · 22 Ill. 2d 73 - Knierim v. Izzo
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Farmer , the plaintiff had brought an action in in state court against his union claiming intentional infliction of emotional distress and unlawful discrimination in job referrals. The case went to trial solely on the emotional distress claim and the plaintiff prevailed. However, the California Court of Appeal reversed, concluding that the entire dispute was subject to the exclusive jurisdiction of the National Labor Relations Board. The United States Supreme Court vacated that decision, ruling that preemption was not appropriate in that particular situation. Utilizing a flexible analysis, the Court considered the nature of the interest being asserted and the potential effect that concurrent judicial and administrative remedies would have on the administration of national labor policies. The Court concluded that the state had a substantial interest in protecting its citizens from outrageous conduct which intentionally inflicted emotional distress. In analyzing the potential for interference with the federal labor scheme, the Court noted that the state tort action could be resolved without requiring any determinations as to the underlying labor dispute, i.e., the existence of any unlawful discrimination. The fact that the N.L.R.B. had no authority to resolve or remedy an emotional distress claim was also deemed significant. Based on those considerations, the Court concluded that preemption was not mandated since a substantial state interest was asserted and its adjudication”
4 later decisions quote this exact passage“[The plaintiff's] allegations do not allege a state tort sufficiently separate from the labor dispute to permit concurrent jurisdiction.”
2 later decisions quote this exact passage“[t]he adjudication of his claim would necessarily involve interpretation of the collective bargaining agreement”
2 later decisions 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.