Mateo v. M/S Kiso’s Empirical Analysis
41 F.3d 1283 · 1994
Citation profile
7 federal appellate · 1 district ·
How this case has been cited
Cited by 9 later decisions — most recently October 2013
7 federal appellate · 1 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
Applies 46 U.S.C. § 10313
Relies on Insurance Co. of North America v. United States Department of Labor · Japan Line, Ltd. v. County of Los Angeles · Stephen P. Havens v. F/t Polar Mist, U.S.C.G. Official Number 604676, in Rem, Arctic Vessel Management, Inc., in Personam · 805 F. Supp. 761 - Mateo v. M/S KISO · Su
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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The phrase “without sufficient cause” must be taken to mean something more than merely valid defenses to a wage claim. Its meaning, in effect, is a wil[l]ful, unreasonable and arbitrary attitude upon the part of the master or shipowner in refusing to pay earned wages to the seamen. It may be a highhanded or capricious action, although not necessarily so. “Without sufficient cause” has been characterized by admiralty courts as arbitrary, unwarranted, unjust, and unreasonable conduct. The presence of good faith or moral justification for refusal to pay undoubtedly has considerable effect in the determination of whether the masterfs] or shipowner’s action was or was not “without sufficient cause.” Generally, where the refusal or failure to pay wages results from an honest difference of opinion arising from a matter in dispute — a dispute about which honest men are apt to differ — the courts will be loathe to declare a penalty when later one of the disputants has been proved wrong. ... [A] showing of good faith upon the part of the master or owner, together with reasonable cause for failure to pay wages due, undoubtedly carries considerable influence in determining whether such refusal is not without sufficient cause. Where the master or owner has acted in a reasonable manner throughout and without any showing of arbitrariness or unjustness, where he had an honest doubt as to the justification of the demand, and where the facts and circumstances surrounding the wage demand are su”
1 later decision quote this exact passage · from the majority“defendants acted in good faith by abiding with the dictates of Philippine law and long-standing custom in paying off the seamen after they had returned to the Philippines”
1 later decision quote this exact passage · from the majority“a willful, unreasonable and arbitrary attitude on the part of the master or shipowner in refusing to pay earned wages to the seamen.”
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.