The Loyal’s Empirical Analysis
204 F. 930 · 1913
Citation profile
13 federal appellate · 16 district ·
How this case has been cited
Cited by 37 later decisions (4 by the Supreme Court) — most recently October 2000 · most notably Luckenbach v. W. J. McCahan Sugar Refining Co. (1918), Pendleton v. Benner Line (1918)
13 federal appellate · 16 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 Wesley Richardson v. Judson Harmon · Work v. Leathers · Quinlan v. Pew · Great Lakes Towing Co. v. Mill Transp. Co. · Harbinger v. Carver
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The purpose of Congress was, as we think, to relieve the shipowner from the consequences of those extraordinary risks which were imposed without limitation by the law of the admiralty as that law had been interpreted in this country. And by extraordinary risks we mean those risks arising from the conduct of, and contracts made by, those who are beyond the personal supervision and control of the owner and yet have legal authority to bind him to answer for their conduct or contracts; or, to express the thought in another way, that the liabilities intended by this legislation were those peculiar to. him as a shipowner and had been imputed to him because of his relation to the ship, and not those liabilities, whether for torts or from contracts, which spring from his own' personal conduct or stipulation. It seems to us altogether unlikely that Congress intended to qualify the power of an owner to make contracts in relation to his ship which by the universal law would be valid if made about anything else and would be enforced in the courts in common-law actions. It would be an anomaly that a party competent to do-business should be unable to make a valid contract about his own affairs or be given such an immunity as to make his stipulations of uncertain value.””
1 later decision quote this exact passage · from the majoritye.g. Line v. Pendleton““That the lighter ‘Loyal’ was unseaworthy seems established beyond question. She sprang a leak without having been subjected to any sea peril. The only inference in such circumstances is of unséaworthiness. Besides, the history of the vessel leads to the same conclusion. “The owner of the lighter was under obligation to the owner of the cargo to assume any salvage award caused by unseaworthiness of its vessel. The vessel-owner had a written contract with the cargo-owner for lighterage services covering an extended period. This lighterage contract implied an obli- ■ gation that the lighters to be furnished under it should be seaworthy and if this one were in fact unseaworthy (as we have found she was) and if the unseaworthiness made the salvage services necessary (as it unquestionably did) the salvage award ran properly against the vessel-owner subject to any right to limit its liability.-””
1 later decision 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.