The Chattahoochee’s Empirical Analysis
173 U.S. 540 · 1899
Citation profile
186 federal appellate · 48 district · 6 state decisions
How this case has been cited
Cited by 401 later decisions (31 by the Supreme Court) — most recently January 2005 · most notably Halcyon Lines v. Haenn Ship Ceiling & Refitting Corp. (1952), American Banana Company v. United Fruit Company (1909)
186 federal appellate · 48 district · 6 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 First Circuit Court of Appeals)
Relationships
Relies on The Silvia · The " Scotland" · The Delaware · The "North Star"
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 401 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It has been said by this court, in respect to steamers, that they are bound to reduce their speed to such a rate as will enable them to stop- in time to avoid a collision after an approaching vessel comes in sight, pro vided such approaching vessel is herself going at the moderate speed required by law.””
8 later decisions quote this exact passage · from the majority““But libelants insist in this connection that the act of February, 1893, known as the ‘Harter Act,’ has modified the previous existing relations between the vessel and/her cargo, and has an important bearing upon this branch of the case. P.v the third section of that act, the owner of a seaworthy vessel (and in the absence of proof to the contrary, a vessel will be presumed to be seaworthy) is no longer responsible to the cargo for damage or loss resulting from errors in navigation.””
5 later decisions quote this exact passage · from the majoritye.g. The Wildcroft · The Wildcroft““But if the doctrine of the Xorth Star, he a sound one, that in Cases’of mutual fault the owner of a vessel which, lias been totally lost by‘Collision is not entitled to the benefit of an act limiting his liability to the other vessel until, after the balance of damage has been struck, it would seem to follow that the sunken vessel is not entitled to the benefit of any statute tending to lessen its liability to the other vessel, or to an increase of the burden of such other vessel, until the amount of such liability has been .fixed upon the principle of an equal division of damages. This is in effect extending the doctrine of the Delaware Case, wherein the question of liability for the loss of the cargo was not in issue, to one where the vessel suffering the greater injury is also the carrier of a cargo. In other words, if the .'Harter act was not intended to increase the liability of one vessel towards the other in a collision case, the relations of the two colliding vessels to each other remain unaffected by this act, notwithstanding one or both of such vessels be laden with a cargo. We are therefore of opinion that the court of appeals did not err in deducting half the value of the cargo from half the value of the sunken schooner, and in limiting a recovery' to the difference ' between these values. The decree is affirmed.””
1 later decision quote this exact passage · from the majoritye.g. The George W. Roby
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.