Norwood v. Kirkpatrick’s Empirical Analysis
1955
Citation profile
261 federal appellate · 362 district · 52 state decisions
How this case has been cited
Cited by 1,633 later decisions (17 by the Supreme Court) — most recently June 2024 · most notably Piper Aircraft Co. v. Reyno (1982), Van Dusen v. Barrack (1964)
261 federal appellate · 362 district · 52 state decisions — followed in 12 states
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.
Appellate journey
reviewedAll States Freight, Inc. v. Modarelli (from Third Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 1404 · 29 U.S.C. § 185 (§ 301 of the Labor Management Relations Act of 1947 (Taft-Hartley Act)) · 45 U.S.C. § 51 (Federal Employers' Liability Act) · 45 U.S.C. § 56 (Federal Employers' Liability Act)
Relies on Gulf Oil Corporation v. Gilbert · Wilko v. Swan · Koster v. Lumbermens Mut Casualty Co · Kerotest Mfg Co v. C-O-Two Fire Equipment Co
Cited together with Gulf Oil Corporation v. Gilbert · Van Dusen v. Barrack · Piper Aircraft Co. v. Reyno · Continental Grain Company v. The Fbl-585 · Hoffman v. Blaski
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 1,633 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The forum non conveniens doctrine is quite different from Section 1404(a). That doctrine involves the dismissal of a case because the forum chosen by the plaintiff is so completely inappropriate and inconvenient that it is better to stop the litigation in the place where brought and let it start all over again somewhere else. It is quite naturally subject to careful limitation for it not only denies the plaintiff the generally accorded privilege of bringing an action where he chooses, but makes it possible for him to lose out completely, through the running of the statute of limitations in the forum finally deemed appropriate. Section 1404(a) avoids this latter danger. Its words should be considered for what they say, not with preconceived limitations derived from the forum non conveniens doctrine.”
55 later decisions quote this exact passage · from the majority““For the convenience of parties and witnesses, in the interest of justice, a district court may transfer any civil action to any other district or division where it might have been brought.””
50 later decisions quote this exact passage · from the dissent“[U]nless the balance is strongly in favor of the defendant, the plaintiff's choice of forum should rarely be disturbed.”
10 later decisions quote this exact passage · from the dissent
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.