Fitzgerald v. United States Lines Co.’s Empirical Analysis
1963
Citation profile
338 federal appellate · 94 district · 83 state decisions
How this case has been cited
Cited by 953 later decisions (27 by the Supreme Court) — most recently December 2023 · most notably Moragne v. States Marine Lines, Inc. (1970), Gillespie v. United States Steel Corp. (1964)
338 federal appellate · 94 district · 83 state decisions — followed in 11 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
reviewedFitzgerald v. United States Lines Co. (from Second Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 1331 · 28 U.S.C. § 2073
Relies on Romero v. International Terminal Operating Co. · The Osceola · Mitchell v. Trawler Racer, Inc. · Wilburn Boat Company v. Fireman's Fund Insurance Company · Atlantic & Gulf Stevedores, Inc. v. Ellerman Lines, Ltd.
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 953 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although remedies for negligence, unseaworthiness, and maintenance and cure have different origins and may on occasion call for application of slightly different principles and procedures, they nevertheless, when based on one unitary set of circumstances, serve the same purpose of indemnifying a seaman for damages caused by injury, depend in large part upon the same evidence, and involve some identical elements of recovery.”
46 later decisions quote this exact passage · from the majority“This Court has held that recovery of maintenance and cure does not bar a subsequent action under the Jones Act, . . . but of course, where such closely related claims are submitted to different triers of fact, questions of Res judicata and collateral estoppel necessarily arise . . .”
2 later decisions quote this exact passage · from the majority““I am wholly in sympathy with the result reached by the Court. It is, I believe, a result that is consistent with sound judicial administration and that will greatly simplify the conduct of suits in which a claim for maintenance and cure is joined with the Jones Act claim arising out of the same set of facts. “But the rule that the Court announces is in my view entirely procedural in character, and the manner in which such rules must be promulgated has been specified by Congress in 28 U.S.C. § 2073 . This statute provides that rules of procedure in admiralty ‘shall not take effect until they have been reported to Congress by the Chief Justice at or after the beginning of a regular session thereof * * * and until the expiration of ninety days after they have been thus reported.’ “ * * * I think the appropriate way to achieve what in this instance is obviously a desirable procedural reform is to deal with the matter through the Judicial Conference of the United States.””
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.