Robert Workman v. Mayor Aldermen and Commonalty of the City of New York a’s Empirical Analysis
179 U.S. 552 · 1900
Citation profile
125 federal appellate · 101 district · 57 state decisions
How this case has been cited
Cited by 431 later decisions (60 by the Supreme Court) — most recently November 2018 · most notably Indian Towing Company v. United States (1955), Southern Pacific Co. v. Jensen (1917)
125 federal appellate · 101 district · 57 state decisions — followed in 14 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
reviewedMayor of New York v. Workman (from Second Circuit Court of Appeals)
Relationships
Relies on The Harrisburg · 'The Ku-Klux Cases' Yarbrough · Bauman v. Ross · Liverpool & Great Western Steam Co. v. Phenix Insurance · The Lottawanna
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 431 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t becomes manifest that the decisions of this court overthrow the assumption that the local law or decisions of a State can deprive of all rights to relief, in a case where redress is afforded by the maritime law and is sought to be availed of in a cause of action maritime in its nature and depending in a court of admiralty of the United States.”
19 later decisions quote this exact passage · from the majority““As a result of the general principle by which a municipal corporation has the capacity to sue and be sued, it follows that there is no limitation taking such corporation out of the reach of process of a court of admiralty, as such courts, within the limit of their jurisdiction, may reach persons having a general capacity to stand in judgment * * * ( 179 U.S. 565 , 21 S.Ct. 217 ) “It results that, in maritime law, the public nature of the service upon which a vessel is engaged at the time of the commission of a maritime tort affords no immunity from liability in a court of admiralty, where the court has jurisdiction. This being so, it follows that as the municipal corporation of the City of New York, unlike a sovereign, was subject to the jurisdiction of the court, the claimed exemption from liability asserted in the case at bar, because of the public nature of the service upon which the fire-boat was engaged — even if such claim for the purposes of the case be conceded — was without foundation in the maritime law, and therefore afforded no reason for denying redress in a court of admiralty for the wrong which the courts below both found to have been committed.” ( 179 U.S. 570 , 21 S.Ct. 218 )”
4 later decisions quote this exact passage · from the concurrence““In the Court of Appeals of the State of New York, the law has long been settled that a municipal corporation having a charter from the State, which requires it to construct and maintain highways and bridges, is liable, to a person suffering injury in per son or property by a defect in the construction or repair of either by the negligence of the commissioner of highways. Hutson v. New York (1853), 9 N. Y. 163 ( 59 Am. Dec. 526 ); Conrad v. Village of Ithaca (1857), 16 N. Y. 158, 161 ; Requa v. City of Rochester (1871), 45 N. Y. 129 ( 6 Am. Rep. 52 ); Hume v. New York (1878), 74 N. Y. 264 ; Ehrgott v. New York (1884), 96 N. Y. 264 ( 48 Am. Rep. 622 ) ; Hughes v. County of Monroe (1895), 147 N. Y. 49, 57 ( 41 N. E. 407 , 39 L. R. A. 33); Missano v. New York (1899), 160 N. Y. 123 ( 54 N. E. 744 ). “But that court has constantly held otherwise in regard to negligence of members of the fire department, the police department, or even of the department of public charities, of public health, or of public instruction. “In Maxmilian v. New York (1875), 62 N. Y. 160 ( 20 Am. Rep. 468 ), which has always been considered a leading case, Judge Folger, delivering the unanimous judgment of the court, said: ‘There are two kinds of duties which are imposed upon a municipal corporation: One is of that kind which arises from the grant of a special power, in the exercise of which the municipality is as a legal individual; the other is of that kind which arises, or is implied, from the use of pol”
1 later decision quote this exact passage · from the dissent
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.