The St. Jago de Cuba’s Empirical Analysis
22 U.S. 409 · 1824
Citation profile
42 federal appellate · 63 district · 6 state decisions
How this case has been cited
Cited by 160 later decisions (20 by the Supreme Court) — most recently April 2010 · most notably Piedmont & Georges Creek Coal Co. v. Seaboard Fisheries Co. (1920), Detroit Trust Co. v. The Thomas Barlum (1934)
42 federal appellate · 63 district · 6 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.
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 160 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““For these purposes the law maritime attaches the power of pledging or subjecting the vessel to materialmen to the office of shipmaster, and considers the owner as vesting him with those powers by the mere act of constituting him shipmaster. The necessities of commerce require that when remote from his owner he should be able to subject his owner’s property to that liability without which it is reasonable to suppose he will not be able to pursue his owner’s interests. But when the owner is present the reason ceases, and the contract is inferred to be with the owner himself, on his ordinary responsibility, without a view to the vessel as the fund from which compensation is to be derived.””
9 later decisions quote this exact passage · from the majoritye.g. The J. E. Rumbell · The Kate““The precedence of forfeiture has never been carried further than to overreach common-law contracts entered into by the owner; and it would be un reasonable to extend them further.” “Forfeiture does not ride over the rights derived under maritime contracts, whether they be called ‘liens’ or ‘privileges.’ ” “In the case of wreckage and salvage, it is unquestionable that forfeitures would ho superseded; and we see no ground on which to preclude ahy other maritime claim really and honestly acquired. We concur in the opinion of the court below that the fair claims of seamen and subsequent material men are not overreached by the previous forfeiture.””
1 later decision quote this exact passage · from the majority““In ease of wreck or salvage it is unquestionable tbat forfeiture would be superseded; and we see no ground on wbicb to preclude any other maritime claim, fairly and honestly acquired. We concur, then, in tlie opinion of the court, below that tbe fair claims of seamen and subsequent material men are not overreached by tbe previous forfeiture,” etc.”
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.