Zappia Middle East Construction Company Limited v. The Emirate of Abu Dhabi, Abu Dhabi Investment Authority, and Abu Dhabi Commercial Bank’s Empirical Analysis
215 F.3d 247 · 2000
Citation profile
35 federal appellate · 12 district ·
How this case has been cited
Cited by 153 later decisions — most recently January 2023 · most notably Valentin v. Hospital Bella Vista (2001), Robinson v. Government of Malaysia (2001)
35 federal appellate · 12 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 Argentine Republic v. Amerada Hess Shipping Corp. · First National City Bank v. Banco Para El Comercio Exterior De Cuba · Alfred Dunhill of London, Inc. v. Republic of Cuba · Fed. Sec. L. Rep. P 95,614 the Exchange National Bank of Chicago v. Touche Ross & Co. · Kamen v. American Telephone & Telegraph Co.
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 153 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A foreign state shall not be immune from the jurisdiction of the courts of the United States or of the States in any case — in which rights in property taken in violation of international law are in issue and that property or any property exchanged for such property is present in the United States in connection with a commercial activity carried on in the United States by the foreign state; or that property or any property exchanged for such property is owned or operated by an agency or instrumentality of the foreign state and that agency or instrumentality is engaged in a commercial activity in the United States....”
8 later decisions quote this exact passage · from the majority“On a Rule 12(b)(1) motion challenging the district court's subject matter jurisdiction, the court may resolve the disputed jurisdictional fact issues by referring to evidence outside of the pleadings, such as affidavits, and if necessary, hold an evidentiary hearing.”
7 later decisions quote this exact passage · from the majority“Freely ignoring the separate status of government instrumentalities would result in substantial uncertainty over whether an instrumentality’s assets would be diverted to satisfy a claim against the sovereign, and might thereby cause third parties to hesitate before extending credit to a government instrumentality without the government’s guarantee. As a result, the efforts of sovereign nations to structure their governmental activities in a manner deemed necessary to promote economic development and efficient administration would surely be frustrated.”
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.