Doyle v. United States’s Empirical Analysis
1977
Citation profile
17 federal appellate · 1 district · 6 state decisions
How this case has been cited
Cited by 39 later decisions — most recently August 1993 · most notably Donovan v. Robbins (1985), Leger v. Drilling Well Control, Inc. (1979)
17 federal appellate · 1 district · 6 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
Applies 14 U.S.C. § 1 (Coast Guard and Maritime Transportation Act of 2006) · 14 U.S.C. § 86 · 28 U.S.C. § 1333 · 33 U.S.C. § 901 · 33 U.S.C. § 904 · 33 U.S.C. § 905 · 45 U.S.C. § 51 (Federal Employers' Liability Act)
Relies on Indian Towing Company v. United States · Pope & Talbot, Inc. v. Hawn · Moragne v. States Marine Lines, Inc. · United States v. Reliable Transfer Co. · Sea-Land Services, Inc. v. Gaudet
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““This court is of the opinion that the ‘reduce by proportional fault’ theory commends itself particularly in admiralty jurisprudence with its comparative fault doctrine. Since the decisions in Pope & Talbot, Inc. v. Hawn, 346 U.S. 406, 409 , 74 S.Ct. 202, 204 , 98 L.Ed. 143 (1953) and United States v. Reliable Transfer Co., Inc., 421 U.S. 397 , 95 S.Ct. 1708 , 44 L.Ed.2d 251 (1975), it has been settled law that a party to a maritime collision should bear only the proportional share of damages attributable to his fault. Under the ‘reduce by amount paid’ theory, a non-settling defendant could end up paying more than Reliable Transfer dictates (such as here where the defendants have eliminated contribution by dismissing their cross claims with prejudice). The better rule, this court feels, is to respect the aleatory nature of the settlement process and to hold both the plaintiff and settling defendant to their gamble. The plaintiff gambles that the amount he receives in settlement plus the amount recoverable from the non-settling defendant will be greater than he could have recovered if he pursued both actions to judgment (i. e., the plaintiff hopes the settling defendant will pay more than what is eventually determined to be his proportional share of the damages). The settling defendant gambles that the amount he pays in settlement is less than he would be liable to pay, had he gone to judgment. To allow the plaintiff, to, in effect, ‘void’ this bargain and execute against the ”
3 later decisions quote this exact passage · from the majority“In cases where . . . ■ if a private person or property were involved, a proceeding in admiralty could be maintained, any appropriate nonjury proceeding in personam may be brought against the United States .”
2 later decisions quote this exact passage · from the majority“[E]ven if the decision to mark or remove the wreck be regarded as discretionary, there is liability for negligence in marking after the discretion has been exercised and the decision to mark has been made. There is certainly no discretion to mark a wreck in such a way as to constitute a trap for the ignorant or unwary rather than a warning of danger.”
1 later decision quote this exact passage · from the majoritye.g. Magno v. Corros
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.