Case Citator › United States v. Reliable Transfer Co.

United States v. Reliable Transfer Co.

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Supreme Court of the United States
Citation
421 U.S. 397
Decided
Confirmed treatments
2
Flagged citations read
79 of 79
Citing cases (total)
702
Treatment dates
1977
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. United States v. Reliable Transfer Co. has been limited: all 79 flagged citations have been read, and the 2 confirmed treatments are listed below. Complaint of Flota Mercante Grancolombiana, S.A. declined to use Reliable Transfer's proportional-fault rule to impute a carrying vessel's fault to innocent cargo owners.
More on how this was screened

Vana Trading Co. v. S.S. Mette Skou declined to extend the rule beyond collisions and strandings to noncollision cargo damage. The other opinions applied Reliable Transfer or reported its overruling of the divided-damages, major-minor-fault, and related older maritime rules. A vacated Chotin Transportation panel opinion was excluded; the later en banc opinion applied and distinguished Reliable Transfer without adversely treating it. Duplicate copies of the same opinion were read separately without creating duplicate entries.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

702 later cases cite United States v. Reliable Transfer Co.; 79 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on United States v. Reliable Transfer Co.?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Southern District of New York declined to extend Reliable Transfer's proportional-fault rule to impute a carrying vessel's fault to innocent cargo owners or reduce their full recovery from a noncarrying vessel.

    Complaint of Flota Mercante Grancolombiana, S.A. · S.D.N.Y. · filed

    Reliable Transfer was intended to change the rule of damages so that the burden would fall more equitably on those parties whose fault contributed to the collision. It cannot be said, as Hudson urges here, to have altered long-established rules by imputing the fault of the carrying vessel to innocent cargo owners.
    Read the full opinion on CourtListener →

  • The Second Circuit declined to extend Reliable Transfer's proportional-fault rule from collision and stranding cases to a noncollision cargo-damage suit.

    Vana Trading Co. v. S.S. Mette Skou · Second Circuit · filed

    This admiralty cargo suit involves the damage and loss to a shipment of yams. It also represents an invitation to apply to cargo suits the doctrine of proportionate fault recently made applicable to collision and stranding cases by United States v. Reliable Transfer Co., 421 U.S. 397, 95 S.Ct. 1708, 44 L.Ed.2d 251 (1975), an invitation which we decline.
    Read the full opinion on CourtListener →

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