St. Clair v. Righter’s Empirical Analysis

Citation profile

19 federal appellate · 6 district · 8 state decisions

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

1. ““It will be noted that Virginia has included two separate paragraphs, (3) and (4), which deal with jurisdiction predicated on a potentially tortious injury which occurs within the State . . .. This sets the Virginia statute apart from the so-called ‘single-act’ long-arm statutes (notably those of Illinois and New York) which state simply that in personam jurisdiction may be asserted over a person who commits a ‘tortious act’ within the state. . . . Paragraph (4) is considerably more restrictive than paragraph (3), the former requiring that the defendant engage in some persistent course of conduct or derive substantial revenue from goods used or consumed or services rendered within the State for jurisdiction to attach. Therefore, in interpreting the Virginia statute we must attempt to ascertain the legislative purpose behind the inclusion of the two tortious injury paragraphs. “The significant difference between Virginia’s statute and the ‘single-act’ statutes is that the General Assembly saw fit to separate the causal act from the resulting injury. In legislation which bases jurisdiction simply on a ‘tortious act’ committed within the state, it is obvious that the act and injury must coincide, as an act cannot be tortious in the absence of injury. Virginia, on the other hand, refers both to the ‘act or omission’ and the ‘tortious injury’ resulting therefrom. In both paragraphs the tortious injury occurs within Virginia, but in paragraph (3) the causal act also occurs within t”

   2 later decisions quote this exact passage
   e.g. 413 F. Supp. 708 - Timberlake v. Summers · First American First Inc III v. National Association of Bank Women K

2. “(a) A court may exercise personal jurisdiction over a person, who acts directly or by an agent, as to a cause of action arising from the person’s ... its * * * * * (4) causing tortious injury in this Commonwealth by an act or omission outside this Commonwealth if he regularly does or solicits business, or engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed or services rendered, in this Commonwealth; (5) causing injury in this Commonwealth to any person by breach of warranty expressly or impliedly made in the sale of goods outside this Commonwealth when he might reasonably have expected such person to use, consume, or be affected by the goods in this Commonwealth, provided that he also regularly does or solicits business, or engages in any other persistent course of conduct, or derives substantial revenue from goods used or consumed or services rendered in this Commonwealth;”

   2 later decisions quote this exact passage
   e.g. Gundy v. Pioneer Mutual Casualty Co. · 576 F. Supp. 868 - Pennington v. McDonnell Douglas Corp.

3. “[a] court may exercise personal jurisdiction over a person, who acts directly or by an agent, as to a cause of action arising from the person’s ... [cjausing tortious injury by an act or omission in this Commonwealth.”

   2 later decisions quote this exact passage
   e.g. Gundy v. Pioneer Mutual Casualty Co. · 580 F. Supp. 1082 - Davis v. Costa-Gavras