The G. R. Booth’s Empirical Analysis
171 U.S. 450 · 1898
Citation profile
59 federal appellate · 37 district · 43 state decisions
How this case has been cited
Cited by 184 later decisions (17 by the Supreme Court) — most recently March 1998 · most notably The Southwark (1903), T. Smith & Son, Inc. v. Taylor (1928)
59 federal appellate · 37 district · 43 state decisions — followed in 10 states
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 Milwaukee and Saint Paul Railway Company v. Kellogg · Liverpool & Great Western Steam Co. v. Phenix Insurance · Phœnix Insurance v. Erie & Western Transportation Co. · Insurance Company v. Boon · Insurance Company v. Tweed
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 184 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In the case at bar, the explosion of the case of detonators, besides doing other damage, burst open the side of the ship below the water line, and the sea water rapidly flowed in through the opening made by the explosion, and injured the plaintiff’s sugar. The explosion, in consequence of which, and through the hole made by which, the water immediately entered the ship, must be considered as the predominant, the efficient, the proximate, the responsible cause of the damage to the sugar, according to each of the tests laid down in the judgments of this court, above referred to. The damage to the sugar was an effect which proceeded inevitably, and of absolute necessity, from the explosion, and must therefore be ascribed to that cause. The explosion concurred, as the efficient agent, with the water, at the instant when the water entered the ship. The inflow of the water, seeking a level by the mere force of gravitation, was not a new and independent cause, but was a necessary and instantaneous result and' effect of the bursting open of the ship’s side by the explosion. There being two concurrent causes of the damage —the explosion of the detonators, and the inflow of the water—without any appreciable interval of time, or any possibility of distinguishing the amount of damage done by each, the explosion, as the cause which set the water in motion, and gave it its efficiency for harm at the time of the disaster, must be regarded as the predominant cause. It was the primary and ef”
5 later decisions quote this exact passage · from the majority““The proximate cause is . the efficient cause, the one that necessarily sets the other causes in operation. The causes that are merely incidental or instruments of a superior or controlling agency are not the proximate causes and the responsible ones, though they may be nearer in time to the result. It is only when the causes are independent of each other that the nearest is, of course, to be charged with the disaster.””
3 later decisions quote this exact passage · from the majority““The fire occurred while the attack was in progress, and when it was about being successful. The attack, as a cause, never ceased to operate until the loss was complete. It was the causa causans which set in operation every agency that contributed to the destruction.””
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.