Sun Oil Co. v. Dalzell Towing Co.’s Empirical Analysis
287 U.S. 291 · 1932
Citation profile
127 federal appellate · 36 district · 17 state decisions
How this case has been cited
Cited by 335 later decisions (19 by the Supreme Court) — most recently August 2007 · most notably Bisso v. Inland Waterways Corp. (1955), Southwestern Sugar and Molasses Co v. River Terminals Corporation (1959)
127 federal appellate · 36 district · 17 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.
Appellate journey
reviewedSun Oil Co. v. Dalzell Towing Co. (from Second Circuit Court of Appeals)
Relationships
Relies on Liverpool & Great Western Steam Co. v. Phenix Insurance · Stevens v. The White City · Railroad Company v. Lockwood · Santa Fe, Prescott & Phœnix Railway Co. v. Grant Bros. Construction Co.
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 335 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“When the captain of any tug engaged in the services of towing a vessel * * * goes on board said vessel, it is understood and agreed that said tugboat captain becomes the servant of the owners in respect to the giving of orders to any of the tugs engaged in the towage service and in respect to the handling of such vessel, and neither the tugs nor their owners or agents shall be liable for any damage resulting therefrom.”
6 later decisions quote this exact passage · from the majority“The provision that its tug captains while upon the assisted ship would be the servants of her owner is an application of the well-established rule that when one puts his employee at the disposal and under the direction of another for the performance of service for the latter, such employee while so engaged acts directly for and is to be deemed the employee of the latter and not of the former.”
3 later decisions quote this exact passage · from the majority“Respondent [tug owner] had no exclusive privilege or monopoly in respect of the services that petitioner desired to have performed for its tanker. And petitioner was under no compulsion to accept the terms of respondent's pilotage clause. There is nothing to suggest that the parties were not on equal footing or that they did not deal at arm's length.”
3 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.