The St. Paul’s Empirical Analysis
277 F. 99 · 1921
Citation profile
5 federal appellate · 4 district ·
How this case has been cited
Cited by 16 later decisions — most recently June 2002
5 federal appellate · 4 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 The John G. Stevens · the Schooner Freeman v. Alvah Buckingham · Dupont De Nemours Co v. John Vance et al. · The Maggie Hammond · The Eddy
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 16 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The cargo owners, under their contract, were entitled to such delivery of their goods. To the extent that those goods were not so delivered in sound condition, and that costs and expenses were incurred in connection therewith, the cargo owners have been damaged. Because there was deviation, unexcused, because, of failure of compliance with the Harter Act, the principle applies that the shipowner becomes an insurer and is liable for all loss and damage, even unavoidable casualty. Carver on Carriage by Sea (6th Ed.) § 287; The Citta Di Messina, supra. Once the deviation occurs, it becomes immaterial how the damages are occasioned.””
1 later decision quote this exact passage · from the majoritye.g. The Pelotas“From the moment, therefore, that the cargo was aboard the St. Paul, the lien attached. It is argued, however, that this lien was `inchoate,' in the meaning of not being perfected.... It is `inchoate' only in the sense of enforceability. In other words, the lien is discharged, ipso facto, when the ship performs its duty to the cargo. If it does not, then the enforcement `relates back to the period when it first attached'; for the lien is born and exists, until discharged, from the moment the cargo is aboard.”
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.