Scott v. Ira Chaffee’s Empirical Analysis
2 F. 401 · 1880
Citation profile
11 federal appellate · 15 district ·
How this case has been cited
Cited by 34 later decisions (4 by the Supreme Court) — most recently November 1956 · most notably Osaka Shosen Kaisha v. Pacific Export Lumber Co. (1923), Krauss Bros. Lumber v. Dimon Steamship Corp. (1933)
11 federal appellate · 15 district ·
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.
Relationships
Relies on Robert Vandewater v. Edward Mills · the Schooner Freeman v. Alvah Buckingham · Henry Bulkley v. The Naumkeag Steam Cotton Company · The Keokuk
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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It must now be considered as settled that if the ship enters upon the performance of its work or any step has been taken towards such performance, the ship becomes pledged to the complete execution of the contract and may be proceeded against in rem for a nonperformance.””
3 later decisions quote this exact passage““From tills review of the cases it will be seen that, with the exception of the dictum In the case of The Williams, there is no authority for saying that a court of lutmiralfy has jurisdiction in rem for the breach of a purely executory contract. 1 re is reason as well as authority for the proposition. If the owner oí a oar¡¡.o has a privilege upon the vessel for a breach of his contract, the vessel would be entitled equally to a lien on the cargo for a refusal of the owner to put it on hoard, and it might be seized upon the dock or anywhere else for the satisfaction of such lien. IC the jurisdiction is sustained in this class of cases, it ought also to include cases of contract to repair the vessel or supply her with stores, in which the materialman would-be entitled to a lien, though nothing had been done under the contract. 1 lind it impossible to say with Judge Emmons, in the case of The Williams, that, the dicta in The Freeman and The Yankee Blade are 'now expressly overruled.’ While tlie point has not been directly adjudicated in the court of last resort, i find no intimation in any of the later cases of a disposition on the part of that tribunal to recede from the doctrine there announced.””
1 later decision quote this exact passagee.g. The Strathnairn““But this duty of the vessel, to the performance of which the law binds her by hypothecation, is to deliver the cargo at the time and place stipulated in the bill of lading or charter party,, without injury or deterioration. If the cargo be not placed on board, it is not bound to the vessel, and the vessel cannot be in default for the nondelivery, in good order, of goods never received on board.””
1 later decision quote this exact passage
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.