Velandra v. Regie Nationale Des Usines Renault’s Empirical Analysis
336 F.2d 292 · 1964
Citation profile
36 federal appellate · 10 district · 11 state decisions
How this case has been cited
Cited by 104 later decisions — most recently May 2016 · most notably Southern Machine Co. v. Mohasco Industries, Inc. (1968), Wells Fargo & Co. v. Wells Fargo Express Co. (1977)
36 federal appellate · 10 district · 11 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
Applies 28 U.S.C. § 1653
Relies on Erie Co v. Tompkins · International Shoe Co. v. Washington · McGee v. International Life Insurance · Cannon Mfg Co v. Cudahy Packing Co · 22 Ill. 2d 432 - Gray v. American Radiator & Standard Sanitary 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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he law relating to the fictions of agency and of separate corporate entity was developed for purposes other than determining amenability to personal jurisdiction, and the law of such amenability is merely confused by reference to these inapposite matters. The International Shoe decision represented an effort by the Supreme Court to clarify earlier concepts in the area of the amenability of foreign corporations to the personal jurisdiction of state courts by sweeping aside any lingering notions that the earlier shibboleths of ‘consent,’ ‘presence,’ and ‘doing business’ were self-defining abstractions, and by redefining those tests in terms of ‘minimum contacts.’ Following this decision it would seem appropriate, for the purpose of determining the amenability to jurisdiction of a foreign corporation which happens to own a subsidiary corporation carrying on local activities, to inquire whether the parent has the requisite minimum contacts with the State of the forum. Thus the ownership of the subsidiary carrying on local activities in Michigan represents merely one contact or factor to be considered in assessing the existence or non-existence of the requisite minimum contacts with the State of Michigan, but is not sufficient of itself to hold the present foreign corporations amenable to personal jurisdiction.”
4 later decisions quote this exact passage · from the majority““[4] Considering first the chain of corporate ownership, Regie owns 100% of the stock of Renault, and Renault in turn owns 100% of the stock of Great Lakes, which, as indicated, carries on substantial economic activities within the State of Michigan. However, the mere ownership by a corporation of all of the stock of a subsidiary amenable to the jurisdiction of the courts of a state may not alone be sufficient to justify holding the parent corporation likewise amenable.13 In the early case of Cannon Mfg. Co. v. Cudahy Packing Co.,14 the Supreme Court held that the activities of a subsidiary did not subject its parent corporation to the personal jurisdiction of local courts. It should be noted that the ruling of the Cannon case, if not qualified by the subsequent ruling in the International Shoe Company case, has been at least qualified in later cases holding foreign corporations amenable to the personal jurisdiction of local courts because of the local activities of subsidiary corporations upon the theory that the corporate separation is fictitious,15 or that the parent has held the subsidiary out as its agent,16 or, more vaguely, that the parent has exercised an undue degree of control over the subsidiary.17 ” (emphasis added) (footnotes omitted)”
4 later decisions quote this exact passage · from the majority““In determining whether minimum contacts exist on the basis of the presence or sale of a product within a state, the extent of the contact is related to a number of factors, including the number and value of sales within the state, their ratio to the total market for like or similar products within the state, the quantity or value of the defendant’s production, the percentage of the total output sold within the state, as well as the nature of the product, particularly with reference to whether it is inherently dangerous or not.””
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.