Flint v. Christall’s Empirical Analysis
171 U.S. 187 · 1898
Citation profile
81 federal appellate · 84 district · 5 state decisions
How this case has been cited
Cited by 248 later decisions (26 by the Supreme Court) — most recently February 2014 · most notably The Southwark (1903), The Chattahoochee (1899)
81 federal appellate · 84 district · 5 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.
Appellate journey
reviewedthe decision below (from Second Circuit Court of Appeals)
Relationships
Relies on Liverpool & Great Western Steam Co. v. Phenix Insurance · The Caledonia · The Edwin Morrison Bradley Fertilizer Co v. Lavender · Ralli v. Troop
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 248 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““mainly, the main purposes of the act were to relieve the shipowner from liability for latent defects not discoverable by the utmost care and diligence, and, in event that lie lias exercised due diligence to make his vessel seaworthy, it exempts him and the ship from responsibility for damage or loss resulting from faults or errors in navigation or management.””
5 later decisions quote this exact passage · from the majority““If tbe owner of the ship shall have exercised due diligence to make said ship in all respects seaworthy and properly manned, equipped and supplied, it is hereby agreed that in case of danger, damage or disaster resulting from fault or negligence of the pilot, master or crew in the navigation or management of the ship, or from latent or other defects, or unseaworthiness of the ship, whether existing at the time of shipment, or at the beginning of the voyage, but not discoverable by due diligence, the consignees or owners of the cargo shall not be exempted from liability for contribution in General Average, or for any special charges incurred, but, with the shipowner shall contribute in General Average, and shall pay such special charges, as if such danger, damage or disaster had not resulted from such fault, negligence, latent, or other defects or unseaworthiness.””
2 later decisions quote this exact passage · from the majority““But we tbink that for the courts to declare, as a consequence of this legislation, that the ship owner is not only relieved from liability for the negligence of his servants, but is entitled to share in a general average rendered necessary by that negligence, would be in the nature of a legislative act. The act in question does, undoubtedly, modify the public policy as previously declared by the courts, but if Congress had intended to grant the further privilege now contended for it would have expressed such an intention in unmistakable terms. It is one thing to exonerate the ship and its owner from liability for the negligence of those who manage the vessel; it is another thing to authorize the ship owner to do what he could not do before, namely, share in the general average occasioned by the mismanagement of the master and crew.””
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.