Dole Food Company Inc v. Watts’s Empirical Analysis
303 F.3d 1104 · 2002
Citation profile
37 federal appellate · 37 district · 7 state decisions
How this case has been cited
Cited by 176 later decisions — most recently April 2025 · most notably Schwarzenegger v. Fred Martin Motor Co. (2004), Yahoo! Inc. v. La Ligue Contre Le Racisme et L'Antisemitisme (2006)
37 federal appellate · 37 district · 7 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 International Shoe Co. v. Washington · Burger King Corporation v. Rudzewicz · Gulf Oil Corporation v. Gilbert · Asahi Metal Industry Co. v. Superior Court of Cal., Solano Cty. · Piper Aircraft Co. v. Reyno
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 176 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the extent of the defendants’ purposeful injection into the forum state’s affairs; (2) the burden on the defendant of defending in the forum; (3) the extent of the conflict with the sovereignty of the defendant’s state; (4) the forum state’s interest in adjudicating the dispute; (5) the most efficient judicial resolution of the controversy; (6) the importance of the forum to the plaintiffs interest in convenient and effective relief; and (7) the existence of an alternative forum.”
13 later decisions quote this exact passage · from the concurrence“[t]he non-resident defendant must purposefully direct his activities or consummate some transaction with the forum or resident thereof; or perform some act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws.”
10 later decisions quote this exact passage · from the majority“(1) committed an intentional act, (2) expressly aimed at the forum state, (3) causing harm that the defendant knows is likely to be suffered in the forum state.”
7 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.