Vaughan v. Atkinson’s Empirical Analysis
1962
Citation profile
619 federal appellate · 159 district · 258 state decisions
How this case has been cited
Cited by 1,808 later decisions (23 by the Supreme Court) — most recently March 2025 · most notably Alyeska Pipeline Service Company v. Wilderness Society (1975), Roadway Express, Inc. v. Piper (1980)
619 federal appellate · 159 district · 258 state decisions — followed in 18 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
reviewedVaughan v. Atkinson (from Fourth Circuit Court of Appeals)
Relationships
Relies on Sprage v. Ticonic Nat Bank · Kossick v. United Fruit Co. · Swift & Co. Packers v. Compania Colombiana Del Caribe, S. A. · Calmar Ss Corporation v. Taylor
Cited together with Alyeska Pipeline Service Company v. Wilderness Society · Calmar Ss Corporation v. Taylor · Farrell v. United States · Aguilar v. Standard Oil Co. · Cortes v. Baltimore Insular Line, Inc.
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 1,808 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Maintenance and cure is designed to provide a seaman with food and lodging when he becomes sick or injured in the ship's service; and it extends during the period when he is incapacitated to do a seaman's work and continues until he reaches maximum medical recovery.”
64 later decisions quote this exact passage · from the majority““Maintenance and cure differs from rights normally classified as contractual. As Mr. Justice Cardozo said in Cortes v. Baltimore Insular Line, supra, 371 [of 287 U.S. 367 , 174 of 53 S.Ct. 173 , 77 L.Ed. 368 ], the duty to provide maintenance and cure ‘is imposed by the law itself as one annexed to the employment. . . . Contractual it is in the sense that it has its source in a relation which is contractual in origin, but given the relation, no agreement is competent to abrogate the incident.’ [Footnote omitted.] ” 3”
12 later decisions quote this exact passage · from the majority“"[I]f the shipowner’s refusal to pay maintenance stemmed from a wanton and intentional disregard of the legal rights of the seaman, the latter would be entitled to exemplary damages in accord with traditional concepts of the law of damages. McCormick, Damages, § 79. While the amount so awarded would be in the discretion of the fact finder, and would not necessarily be measured by the amount of counsel fees, indirect compensation for such expenditures might thus be made.” Id. at 540 , 82 S.Ct. at 1004 .”
10 later decisions quote this exact passage · from the dissent
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.