Patterson v. Bark Eudora E’s Empirical Analysis
190 U.S. 169 · 1903
Citation profile
84 federal appellate · 54 district · 48 state decisions
How this case has been cited
Cited by 332 later decisions (47 by the Supreme Court) — most recently December 2017 · most notably Caminetti v. United States (1917), Nebbia v. People of State of New York (1934)
84 federal appellate · 54 district · 48 state decisions — followed in 18 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 Third Circuit Court of Appeals)
Relationships
Relies on Allgeyer v. State of Louisiana · United States v. Fisher · Robertson v. Baldwin · Frisbie v. United States
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 332 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“,“(a) That it shall be, and is hereby, made unlawful in any ease to pay any seaman wages in advance of the time when he has actually earned the same, or to pay such advance wages to any other person. Any person paying such advance wages shall be deemed guilty of a misdemeanor, and upon conviction shall be punished by a fine not less than four times the amount of the wages so advanced, and may also be imprisoned for a period not exceeding six months, at the discretion of the court. The payment of such advance wages shall in no ease, excepting as herein provided, absolve the vessel or the master or owner thereof from full payment of wages after the same shall have been actually earned, and shall be no defense to a libel, suit, or actiou for the recovery of such wages. If any person shall demand or receive, 'either directly or indirectly, from any seaman or other person seeking employment as seaman, or from any person on his behalf, any remuneration whatever for providing him with employment, he shall for every such offense be liable to a penalty of not more than one hundred dollars. * * * CO That this section shall apply as well to foreign vessels as to vessels of the United States; and any master, owner, consignee, or agent of any foreign vessel who has violated its provisions- shall be liable to the same penalty that the master, owner, or agent of a vessel of the United States would be for a similar violation: provided, that treaties in force between the United States and for”
5 later decisions quote this exact passagee.g. Sandberg v. McDonald · The Alnwick“-if the necessities of the public justify the enforcement of a sailor's contract by exceptional means, justice requires that the rights of the sailor be in like manner protected.””
4 later decisions quote this exact passage · from the majoritye.g. Sandberg v. McDonald · The Amelia““Yet when a foreign merchant vessel comes into our ports, like a foreign citizen coming into our territory, it subjects itself to the jurisdiction- of this country. * * * It follows from these decisions that it is within the power of Congress to prescribe the penal provisions of section 10, and no one within the jurisdiction of the United States can escape liability for a violation of those provisions on the plea that he is a foreign citizen or an officer of a foreign merchant vessel. It also follows that it is a duty of the courts of the United States to give full force and effect to such provisions. It is not pretended that this government can control the action of foreign tribunals. In any case presented to them) they will be guided by their own views of the law and its scope and effect, but the courts of the United States are bound to accept this legislation and enforce it whenever its provisions are violated. * * * And this legislation, as plainly as words can make it, imposes these conditions upon the shipment of sailors in our harbors, and declares that they are applicable to foreign as well as to domestic vessels. Congress has thus prescribed feonditions which attend the entrance of foreign vessels into our ports, and those conditions the courts are not at liberty to dispense with.””
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.