Steffens v. Brotherhood of Railway’s Empirical Analysis
797 F.2d 442 · 1986
Citation profile
27 federal appellate · 2 district ·
How this case has been cited
Cited by 49 later decisions — most recently August 2017 · most notably Davenport v. International Brotherhood of Teamsters (1999), Bennett v. Local Union No. 66, Glass, Molders, Pottery, Plastics & Allied Workers International Union (1992)
27 federal appellate · 2 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
Applies 28 U.S.C. § 1331 · 28 U.S.C. § 1337 · 29 U.S.C. § 141 (§ 1 of the Labor Management Relations Act of 1947 (Taft-Hartley Act)) · 29 U.S.C. § 185 (§ 301 of the Labor Management Relations Act of 1947 (Taft-Hartley Act)) · 45 U.S.C. § 151 (Railway Labor Act) · 45 U.S.C. § 152 (Railway Labor Act) · 45 U.S.C. § 153 (Railway Labor Act)
Relies on Steele v. Louisville & Nashville Railroad · Union Pacific Railroad v. Sheehan · Glover v. St. Louis-San Francisco Railway Co. · Tunstall v. Brotherhood of Locomotive Firemen & Enginemen · Strong v. United States
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 49 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Under the LMRA the plaintiff's claim against the employer is brought under Sec. 301, 29 U.S.C. Sec. 185 , but a[n] RLA plaintiff may not bring a direct claim against the employer because there is no corresponding jurisdictional base [in the RLA]. Instead, the employer is merely joined as a party in the duty of fair representation action. To that extent, such a suit is not a 'true' hybrid action.”
2 later decisions quote this exact passage · from the majority“[t]he RLA affords an employee an implied right of action against his union for breach of the duty of fair representation.... An employee may join in this action against the employer and assert that the collective bargaining agreement has been breached if he can allege that the employer's conduct somehow contributed to the union's breach.”
2 later decisions quote this exact passage · from the majority“disagreement with the result [of the Board's decision]”
2 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.