Case Citator › Minturn v. Maynard

Minturn v. Maynard

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

Overruled
Court
Supreme Court of the United States
Citation
58 U.S. 477
Decided
Confirmed treatments
2
Flagged citations read
20 of 20
Citing cases (total)
20
Treatment dates
1984–1991
Overruled
A reviewed court has overruled this case. Minturn v. Maynard was overruled by the Supreme Court in Exxon Corp. v. Central Gulf Lines, Inc. The Court rejected a categorical exclusion of agency contracts from admiralty jurisdiction and directed courts to examine the services performed under the contract. Before that ruling, the Second Circuit criticized the exclusion but followed it.
More on how this was screened

All 20 flagged citations have been read, and the 2 confirmed treatments are listed below.

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.

20 later cases cite Minturn v. Maynard; 20 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 Minturn v. Maynard?

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

Overruled

  • The Supreme Court overruled Minturn's categorical exclusion of agency contracts from admiralty jurisdiction.

    Exxon Corp. v. Central Gulf Lines, Inc. · Supreme Court of the United States · filed

    We conclude that Minturn is incompatible with current principles of admiralty jurisdiction over contracts and therefore should be overruled. We emphasize that our ruling is a narrow one. We remove only the precedent of Minturn from the body of rules that have developed over what types of contracts are maritime. Rather than apply a rule excluding all or certain agency contracts from the realm of admiralty, lower courts should look to the subject matter of the agency contract and determine whether the services performed under the contract are maritime in nature.
    Read the full opinion on CourtListener →

Criticized

  • The Second Circuit criticized Minturn's exclusion of general agency contracts while following it until the Supreme Court could revisit the rule.

    Peralta Shipping Corp. v. Smith & Johnson (Shipping) Corp. · Second Circuit · filed

    However, we are not free to anticipate the Supreme Court’s overruling of Minturn v. Maynard, though we would welcome it.
    Read the full opinion on CourtListener →

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