The Poznan’s Empirical Analysis
9 F.2d 838 · 1925
Citation profile
9 federal appellate · 5 district · 1 state decisions
How this case has been cited
Cited by 41 later decisions — most recently November 2018 · most notably New York Dock Co v. The Poznan (1927), Equilease Corporation v. M/v Sampson (1986)
9 federal appellate · 5 district · 1 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.
Appellate journey
Relationships
Relies on Trustees v. Greenough · United States v. Carver · The Lottawanna · Piedmont & Georges Creek Coal Co. v. Seaboard Fisheries Co. · Walker v. Brown
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.
“[The maritime lien] is given by the law, and it gives the creditor a special property in the ship, which subsists from the moment the debt arises, and it gives him a right to have the ship sold that his debt may be paid out of the proceeds of the sale.”
4 later decisions quote this exact passage“"In Hughes on Admiralty (2d Ed.) 22, it Is said: ‘The same transaction may be maritime in one case and not maritime in another. As emphasizing this distinction, there is the maxim that “a ship is made to plough the seas, and not to lie at the walls.” Hence wharfage rendered to a ship while loading or unloading, or in her regular use as a freight-earning enterprise, is a maritime contract. On the other hand, wharfage to a ship laid up for the winter while waiting for the season to open is not maritime.’ “The same distinction is illustrated by the cases which hold that watchmen on a vessel while in port during voyages are regarded as serving under a maritime contract, but those who have charge of her while laid up have no such contract. Erinagh (D.C.) 7 F. 231 ; Fortuna (D.C.) 206 F. 573 ; Hughes on Admiralty (2d Ed.) 22. And If a vessel is laid up for the season, or for any reason is withdrawn from navigation a contract for wharfage is regarded as a nonmaritime one. Benedict’s Admiralty (5th Ed.) vol. 1, § 66.””
2 later decisions quote this exact passage“the lien ... attaches from the moment the goods are laden on board.”
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.