Sacramento Nav Co v. Salz’s Empirical Analysis
273 U.S. 326 · 1927
Citation profile
158 federal appellate · 70 district · 30 state decisions
How this case has been cited
Cited by 466 later decisions (24 by the Supreme Court) — most recently October 2018 · most notably Atlantic Cleaners & Dyers, Inc. v. United States (1932), Helvering v. Stockholms Enskilda Bank (1934)
158 federal appellate · 70 district · 30 state decisions — followed in 10 states
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
reviewedSacramento Nav. Co. v. Salz (from Ninth Circuit Court of Appeals)
Relationships
Relies on United States v. Hartwell · The Main v. Williams · Liverpool, Brazil & River Plate Steam Navigation Co. v. Brooklyn Eastern District Terminal · United States v. Corbett
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 466 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] contract includes, not only the promises set forth in express words, but, in addition, all such implied provisions as are indispensable to effectuate the intention of the parties and as arise from the language of the contract and the circumstances under which it was made.”
7 later decisions quote this exact passage · from the majority“the employment of one vessel to expedite the voyage of another.”
5 later decisions quote this exact passage · from the majority““This court held (in Liverpool) that it was necessary to surrender only the active tug, saying ‘that for the purposes of liability the passive instrument of the harm does not become one with the actively responsible vessel by being attached to it.’ But this is far from saying that the entire flotilla might not be regarded as one vessel for the purposes of the undertaking in which the common owner was engaged at the time of the collision. The distinction seems plain. There the libel was for an injury to a ship in no way related to the flotilla. It was a pure tort; no contractual obligations were involved; and the simple inquiry was, What constituted the ‘offending vessel’? Here we must ask, What constituted the vessel by which the contract of transportation was to be effected ? a very different question.””
4 later decisions 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.