The Flottbek’s Empirical Analysis
118 F. 954 · 1902
Citation profile
18 federal appellate · 5 district ·
How this case has been cited
Cited by 31 later decisions — most recently October 2016 · most notably David Evanow Phillip Albee Raymond Dunham v. M/v Neptune, a Tug, Her Engines, Tackle, MacHinery & Etc., in Rem Barge Krs 160-6, Her Engines, Tackle, MacHinery Etc., in Rem Dahl Tug & Barge Company Port Gardner Tug & Barge Co., Inc. Krs Marine Inc. Tacoma Boat Building Company, David Evanow Phillip Albee Raymond Dunham v. M/v Neptune, a Tug, Her Engines, Tackle, MacHinery & Etc., in Rem Barge Krs 160-6, Her Engines, Tackle, MacHinery Etc., in Rem Dahl Tug & Barge Company Port Gardner Tug & Barge Co., Inc. Krs Marine Inc. Tacoma Boat Building Company (1998), The S. C. Schenk (1907)
18 federal appellate · 5 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 The Blackwall · The "Sabine" · Commander-in-chief · The Barque Island City · McConnochie v. Kerr
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A salvage service is a service which is voluntarily rendered to a vessel needing assistance, and is designed to relieve her from some distress of danger either present or to be reasonably apprehended. A towage service is one which is rendered for the mere purpose of expediting her voyage, without reference to any circumstances of danger.””
2 later decisions quote this exact passage · from the majoritye.g. The S. C. Schenk · Willis A. Holden““Salvage is decreed by courts of admiralty as a reward for services successfully rendered in saving property from maritime damage, not on the principle of a quantum meruit, or as compensatory remuneration, but as a reward for perilous services, and as an inducement to seamen and others to readily engage in such undertakings and assist in saving life and property. Danger, peril, and a successful deliverance therefrom, either by voluntary effort, special request of, or by contract with the owner, constitutes a case of salvage, whether rendered by one or more salvors. Each salvor that renders a meritorious service, directly aiding in .the rescue and saving of the property, is entitled to a salvage award.””
1 later decision quote this exact passage · from the majoritye.g. Willis A. Holden““There is a-marked and clear distinction between a towage and a salvage service. AVhen a tug is called or taken by a sound vessel as a mere means of saving time, or from considerations of convenience, the service is classed as towage; but if the vessel is disabled, and in need of assistance, it is a salvage service. In cases of simple towage, only a reasonable compensation is allowed, as upon a quantum meruit. In case of salvage, the award is upon a broader and more liberal scale, as we have before stated.””
1 later decision quote this exact passage · from the majoritye.g. Willis A. Holden
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.