Watz v. Zapata Off-Shore Co.’s Empirical Analysis
431 F.2d 100 · 1970
Citation profile
91 federal appellate · 2 district · 4 state decisions
How this case has been cited
Cited by 145 later decisions (1 by the Supreme Court) — most recently March 2016 · most notably Cooper Stevedoring Company Inc v. Fritz Kopke Inc (1974), Leather's Best, Inc., Plaintiff-Appellee-Cross v. S.S. Mormaclynx, Defendants-Appellants-Appellees (1971)
91 federal appellate · 2 district · 4 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.
Relationships
Relies on Seas Shipping Co. v. Sieracki · Palsgraf v. Long Island R.R. Co. · MacPherson v. . Buick Motor Co. · Kermarec v. Compagnie Generale Transatlantique · Halcyon Lines v. Haenn Ship Ceiling & Refitting Corp.
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 145 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““We conclude that the district court had admiralty jurisdiction of Watz’s complaint against Eaton [impleaded manufacturer]. The Texas statute of limitations therefore does not apply. Instead, we look to the analogous limitations period of the Jones Act, which is three years. 46 U.S.C. § 688 ; Flowers v. Savannah Machine & Foundry Company, 5 Cir. 1962, 310 F.2d 135 . Since the action was brought after this statute had run, Watz bears the burden of proof with regard to the two elements counteracting a laches defense; excuse for the delay and lack of prejudice to the defendant. McMahon v. Pan American World Airways, 5 Cir. 1962, 297 F.2d 268, 270 . “The district court concluded: “That no harm having been shown by reason of the delay for filing the plaintiff’s cause of action and by reason that he did not prevent one witness or any evidence from being heard and by reason of the fact that all the defendants, Zapata Off-Shore Company and Eaton Yale & Towne, Inc., had notice within a matter of months after the occurrence that the doctrine of laches or limitations does not apply.” Watz, supra at 111 .”
1 later decision quote this exact passage · from the concurrence“[T]he limiting factor of tradition * * * requires that the injured shore-based worker be engaged in work traditionally that of a seaman * * * excluding those persons performing such tasks as making major repairs requiring drydocking or special skills.”
1 later decision quote this exact passage · from the concurrence“extensive nature of the work contracted to be done, rather than the specific type of work that each of the numerous shore-based workmen is doing on shipboard at the moment of injury,”
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.