Jackson’s Empirical Analysis
Citation profile
9 district · 5 state decisions
How this case has been cited
Cited by 49 later decisions — most recently January 2026 · most notably Rocio Esmeralda Mercado Soto Linch v. Ronald B. Linch (2015), 769 F. Supp. 2d 1285 - ADVANCED OPTICS ELECTRONICS, INC. v. Robins (2010)
9 district · 5 state decisions
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 Mullane v. Central Hanover Bank & Trust Co. · Insurance Corp. of Ireland v. Compagnie Des Bauxites De Guinee · Williams v. State of North Carolina · Goldblatt v. Town of Hempstead · Semtek International Inc. v. Lockheed Martin Corp.
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.
“Olympiakos, like [the Jackson defendant], knowingly suffered a default judgment to be rendered against it. Like [the Jackson defendant], Olympiakos never challenged the Court’s jurisdiction by appealing the judgment of the original action. Accordingly, under the Fifth Circuit’s reasoning in [Jackson], the Court should require Olympiakos to prove that it was not properly subject to the Court’s jurisdiction before vacating the judgment pursuant to Rule 60(b)(4). 16”
1 later decision quote this exact passage · from the majority“[n]oting that the question who bears the burden of proof in a Rule 60(b)(4) challenge to personal jurisdiction is one that has not been answered for this circuit, ... adopted the view of the Seventh Circuit that once a defendant with notice chooses to suffer a default judgment, he is the party who thereafter must shoulder the burden of proving the absence of personal jurisdiction.”
1 later decision quote this exact passage · from the majority“[There seems to be universal agreement that laches [in bringing a Rule 60(b)(4) motion] cannot cure a void judgment, and no court has denied relief under Rule 60(b)(4) because of delay.”
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.