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← 165 U.S. 264 - The Valencia

The Valencia’s Empirical Analysis

165 U.S. 264 · 1897

Citation profile

164
cited by 164 later decisions
7
cited 7 times by the Supreme Court
2
states following
April 2014
most recently cited

61 federal appellate · 69 district · 3 state decisions

How this case has been cited

Cited by 164 later decisions (7 by the Supreme Court) — most recently April 2014 · most notably United States v. Carver (1923), Dannebrog v. Signal Oil & Gas Co. (1940)

61 federal appellate · 69 district · 3 state decisions

4501897190019101920193019401950196019701980199020002010decided

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.

Appellate journey

reviewedthe decision below (from Second Circuit Court of Appeals)

Relationships

Relies on The J. E. Rumbell · Ralli v. Troop · The Kate · The St. Jago de Cuba

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 164 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. ““In the absence of an agreement, express or implied, for a lien, a contract for supplies made directly with the owner in person is to be taken as made on his ordinary, responsibility, without a view to the vessel as the fund from which compensation is to be derived.””
    5 later decisions quote this exact passage · from the majority
  2. ““If no-lien exists under the maritime law, when supplies are furnished to a vessel upon the order of the master, under circumstances charging the party furnishing them with knowledge that the master cannot rightfully, as against the owner, pledge the credit of the vessel for such supplies, m¡uch less is one recognized under that law where the supplies are furnished, not upon the order of the master, but upon that of the charterer who did not represent the owner in the business of the vessel, but who, as the claimant knew, or by reasonable diligence could have ascertained, had agreed himself to provide and pay for such supplies, and could not, therefore, rightfully pledge the credit of the vessel for them.””
    4 later decisions quote this exact passage · from the majority
  3. ““It is true that libelants delivered the coal in the belief that the vessel, whether a foreign or a domestic one, or by whomsoever owned, would be responsible for the value of such coal. But such a belief Is not sufficient in itself to give a maritime lien. If that belief was founded upon the supposition that the steamship company owned the vessel, no lien wonld exist, because, in the absence of an agreement, express or implied, for a lien, a contract for supplies, made directly with the .owner in person, is to be taken as. made ‘on his ordinary responsibility, without a view to the vessel as the fund from which compensation Is to he derived.’ The St. Jago de Cuba, 9 Wheat. 409 , 416, 417, 9 L. Ed. 122 , 124. And if the belief- ihat the vessel wonld be responsible for the supplies was founded on the supposition that it was run under a charter party, then the libelants are to be taken as having furnished the coal at, the request of the owner pro hac vice (Stephenson v. The Francis, 21 Fed. 715 , 717; The Samuel Marshall, 4 C. C. A. 385 , 54 Fed. 397 , 399), without any express agreement for a lien, and in the absence of any circumstances justifying the inference that the supplies were furnished with an understanding that the yes-sol itself would be responsible for the debt incurred. In the present case we are informed by the record that there was no express agreement for a lien, and that nothing occurred to warrant the inference that either the master or the charterer agreed t”
    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.