The Iroquois’s Empirical Analysis
194 U.S. 240 · 1904
Citation profile
170 federal appellate · 32 district · 24 state decisions
How this case has been cited
Cited by 335 later decisions (30 by the Supreme Court) — most recently November 2014 · most notably Crowell v. Benson (1932), Vaughan v. Atkinson (1962)
170 federal appellate · 32 district · 24 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 Iroquois (from Ninth Circuit Court of Appeals)
Relationships
Relies on The Osceola · Robertson v. Baldwin · Smith v. Burnett · Towson v. Moore
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 335 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A seafaring lifg is a dangerous one, accidents of this kind are particularly liable to occur, and the general principle of law that a person entering a dangerous employment is regarded as assuming the ordinary risks of such employment is peculiarly applicable to the case of seamen.””
4 later decisions quote this exact passage · from the majoritye.g. The Kenilworth · The Van Der Duyn“The real question in the case is: whether the master, knowing his ignorance of surgery, the serious nature of the libellant's injury, the poor accommodations for him in the forecastle, the liability of inflammation setting in, and of the bones not uniting, the fact that he was to be carried through the tropics, where, to an invalid confined in the forecastle the heat would be almost intolerable, he should not, even at the sacrifice of a week, have put into Valparaiso and left the libellant there in charge of the American consul. Upon the other hand: libellant made no complaint of his treatment; did not ask to be taken into an intermediate port, and, so far as appears, the master did not know that the wound was not healing properly. The fact that the ribs had already united probably induced him to believe that the leg had also healed, although a careful examination could not have failed to reveal the truth. We lay no stress upon the fact that the libellant did not ask to be taken into an intermediate port. He was a boy, largely ignorant of his rights and duties. The master was his legal guardian in the sense that it is a part of his duty to look out for the safety and care of his seamen, whether they make a distinct request for it or not.”
1 later decision quote this exact passage · from the majority““The duty to provide proper medical treatment and attendance for seamen falling ill or suffering injury in the service of the ship has been imposed upon the shipowners by all maritime nations. It appears in the earliest codes of continental Europe and was expressly recognized by this court in the recent case of The Osceola, 189 U. S. 158 , 23 Sup. Ct. 483 , 47 L. Ed. 760 . Upon large passenger steamers a physician or surgeon is always employed*, whose duty it is to minister to the passengers and crew in cases of sickness or accident. Of course, this would be impracticable upon an ordinary freighting vessel, where the master is presumed to have some knowledge of the treatment of diseases, and in ordinary cases stands in the place of a physician or surgeon (The Wensleydale [D. C.], 41 Fed. 602 ); but for the further protection of seamen vessels of the class of the Iroquois are compelled by law to be provided with a chest of medicines and with such anti-scorbutics, clothing, and slop chests as the climate, particular trade, and length of the voyage may require. U. S. Comp. St. 1901, pp. 3100-3102, §§ 4569, 4572, 4573.””
1 later decision quote this exact passage · from the majoritye.g. The Margharita
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.