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← 226 F.3d 35 - Microsystems Software Inc et al Scandinavia Online Ab et al Waldo Jaquith Lindsay Haisley and Bennett Haselton

Microsystems Software Inc et al Scandinavia Online Ab et al Waldo Jaquith Lindsay Haisley and Bennett Haselton’s Empirical Analysis

226 F.3d 35 · 2000

Citation profile

32
cited by 32 later decisions
2
states following
August 2024
most recently cited

15 federal appellate · 3 district · 2 state decisions

How this case has been cited

Cited by 32 later decisions — most recently August 2024 · most notably Ruiz v. Bally Total Fitness Holding Corp. (2007), National Ass'n of Chain Drug Stores v. New England Carpenters Health Benefits Fund (2009)

15 federal appellate · 3 district · 2 state decisions

140200020102020decided

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 Warth v. Seldin · Steel Co. v. Citizens for a Better Environment · Zenith Radio Corp. v. Hazeltine Research, Inc. · Rutledge v. United States · Ex parte McCardle

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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Contempt proceedings operate to ensure that nonparties have had their day in court. In order to hold a nonparty in contempt, a court first must determine that she was in active concert or participation with the party specifically enjoined (typically, the named defendant). This means, of course, that the nonparty must be legally identified with that defendant, or, at least, deemed to have aided and abetted that defendant in the enjoined conduct. The existence of such a linkage makes it fair to bind the non-party, even if she has not had a separate opportunity to contest the original injunction, because her close alliance with the enjoined defendant adequately assures that her interests were sufficiently represented.”
    2 later decisions quote this exact passage · from the majority
  2. “an exception to the only a party may appeal rule that allows a nonparty to appeal the denial of a motion to intervene,”
    2 later decisions quote this exact passage · from the majority
  3. “courts are powerless to extend a right of appeal to a nonparty who abjures intervention”
    2 later decisions 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.