McConnochie v. Kerr’s Empirical Analysis
9 F. 50 · 1881
Citation profile
14 federal appellate · 16 district ·
How this case has been cited
Cited by 41 later decisions (1 by the Supreme Court) — most recently September 2016 · most notably Red Cross Line v. Atlantic Fruit Co. (1924), Wijsmuller v. United States (1983)
14 federal appellate · 16 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
Relies on Stevens v. The Railroads · Brooks v. Steamer Adirondack · Atlas Steam-Ship Co. v. Steam-Ship Colon · Padelford v. Boardman · The Steamer Leipsic
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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A salvage service is a service which is voluntarily rendered to a vessel needing assistance, and is designed to relieve her from some distress of danger either present or to be reasonably apprehended. A towage service is one which is rendered for the mere purpose of expediting her voyage, without reference to any circumstances of danger.””
9 later decisions quote this exact passage““AH services rendered at sea to a vessel in danger or distress are salvage services. It is not necessary, I conceive, that the distress should be actual or immediate, or that the danger should be imminent and absolute. It will be sufficient if, at the time the assistance is rendered, the ship has encountered any damage or misfortune which might possibly expose her to destruction if the services were not rendered'.””
2 later decisions quote this exact passagee.g. The Alaska · Willis A. Holden““Without attempting any definition, which may be universally applied, a towage service may be described as the employment of one vessel to expedite the voyage of another when nothing more is required than the accelerating her progress. Many circumstances, it is obvious, may arise in the course of such employment which may convert the service into the nature of a salvage service, as, for example, where a ship in tow is disabled in her hull or rigging, or where she is aground, or where the service itself is necessarily attended with danger or extraordinary labor to the towing vessel.””
1 later decision quote this exact passage
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.