Coffin v. Bowater Inc.’s Empirical Analysis
501 F.3d 80 · 2007
Citation profile
14 federal appellate · 10 district · 2 state decisions
How this case has been cited
Cited by 36 later decisions — most recently April 2021 · most notably Mind & Motion Utah Investments, LLC v. Celtic Bank Corp. (2016), Rockwood v. SKF USA Inc. (2012)
14 federal appellate · 10 district · 2 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 29 U.S.C. § 1102 (§ 402 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 1132 (§ 502 of the Employee Retirement Income Security Act of 1974) · 29 U.S.C. § 141 (§ 1 of the Labor Management Relations Act of 1947 (Taft-Hartley Act)) · 29 U.S.C. § 185 (§ 301 of the Labor Management Relations Act of 1947 (Taft-Hartley Act))
Relies on Firestone Tire and Rubber Company v. Bruch · Textile Workers v. Lincoln Mills of Ala. · Curtiss-Wright Corp. v. Schoonejongen · Barnhart Commissioner of Social Security v. Thomas · Sprague v. General Motors 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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We have stated that “[a]n unambiguous contract must be enforced according to its terms, under both the common law and labor law.” Senior v. NSTAR Elec. & Gas Corp., 449 F.3d 206, 219 (1st Cir.2006). However, in the exceptional case, a latent ambiguity in seemingly clear contract language may require us to consider extrinsic evidence to determine the actual object of the parties’ agreement. See RCI Ne. Sews. Div. v. Boston Edison Co., 822 F.2d 199, 202 (1st Cir.1987). “An ambiguity is latent when the language employed is clear and intelligible and suggests but a single meaning, but some extrinsic fact or extraneous evidence creates a necessity for interpretation or a choice among two or more possible meanings.” Moore v. Pa. Castle Energy Corp., 89 F.3d 791, 796 (11th Cir.1996). For example, a contract may refer to an object by a name that denotes more than one actual thing or the parties may use a term that, while signifying one thing in common parlance, designates something particular within the industry’s jargon. See AM Int’l, Inc. v. Graphic Mgmt. As- socs., 44 F.3d 572, 575 (7th Cir.1995) (giving examples of both scenarios). The classic case of latent ambiguity is Raffles v. Wichelhaus, 2 Hurlstone & Coltman 906, 159 Eng. Rep. 375 (Ex. 1864), in which a contract respecting a shipment of cotton to arrive from a certain port on the ship “Peerless” was found ambiguous when the parties discovered that two ships named “Peerless” had departed from the same port.... Mindful that ”
1 later decision quote this exact passage · from the majoritye.g. In Re Inofin, Inc.“Suppose the parties to [a] contract ... had been members of a trade in which the term 'cotton' was used to refer to guncotton rather than to the cotton used in textiles, The ordinary reader of English would not know about this special trade usage, and so would suppose the contract unambiguous. Again, the [latent] ambiguity is in the reference, that is, the connection between .the word and the object that it denotes.”
1 later decision quote this exact passage · from the majority“The classic case of latent ambiguity is Raffles v. Wichelhaus, 2 Hurlstone & Coltman 906, 159 Eng. Rep. 375 (Ex. 1864), in which a contract respecting a shipment of cotton to arrive from a certain port on the ship”
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.