Wilder v. Inter-Island Steam Navigation Co.’s Empirical Analysis
211 U.S. 239 · 1908
Citation profile
31 federal appellate · 9 district · 19 state decisions
How this case has been cited
Cited by 82 later decisions (6 by the Supreme Court) — most recently August 2014 · most notably Isbrandtsen Co. v. Johnson (1952), State v. Murray (1980)
31 federal appellate · 9 district · 19 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.
Relationships
Relies on Patterson v. Bark Eudora E · Eddy v. O'Hara · Thomson v. Baltimore & Susquehanna Steam Co. · McCarty v. Steam-Propeller City of New Bedford
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“An attachment has but few of the attributes of an execution; the execution contemplated by the statute being the judicial process for obtaining the debt or damages recovered by judgment, and final in its character, while the attachment is but mesne process, which may or may not affect the property seized.”
2 later decisions quote this exact passage · from the majority““We think that these provisions, read in connection with section 4536, necessitate the conclusion that it was intended not only to prevent the seaman from disposing of his wages by assignments or otherwise, but to preclude the right to compel a forced assignment, by garnishee or other similar process, which would interfere with the remedy in admiralty for the recovery of his wages by condemnation of the ship. These provisions would be defeated if the seaman’s wages, to be recovered at the end of the voyage, could be at once seized by an execution or attachment. * * * The evident purpose of the federal statutes, that the seaman shall have his remedy in admiralty, would be defeated, and the seaman, in many cases, be turned ashore with nothing in his pocket, because of judgments seizing his wages, rendered it may be, upon improvident contracts, from which it was the design and very purpose of the admiralty law to afford him protection. “We think that section 4536, construed in the light of the other provisions of the same title, prevents the seizure of the seaman’s wages, not only by writs of attachment issued before judgment, but extends the like protection from proceedings in aid of execution, or writs of attachments, such as are authorized by the Hawaiian statutes, after judgment.””
1 later decision quote this exact passage · from the majority“‘‘Section 4536, therefore, has the effect of not only securing the wages of the seaman from direct attachment or arrestment, but further prevents the assignment or sale of his wages, except in the limited cases we have mentioned, and malíes the payment of such wages valid notwithstanding any ‘attachment, incumbrance or arrestment thereon.’ It seems to be clearly inferable from these provisions that wages which have thus been carefully conserved to the seaman were not intended to be subject to seizure by attachment, either before or after judgment.””
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.