In the Matter of the Complaint of Unterweser Reederei, Gmbh. Zapata Off-Shore Company v. M/s Bremen and Unterweser Reederei Gmbh’s Empirical Analysis
428 F.2d 888 · 1970
Citation profile
29 federal appellate · 3 district · 2 state decisions
How this case has been cited
Cited by 68 later decisions (1 by the Supreme Court) — most recently April 2023 · most notably M/s Bremen v. Zapata off-Shore Company (1972), Coastal Steel Corporation v. Tilghman Wheelabrator Ltd Wheelabrator-Frye Inc (1983)
29 federal appellate · 3 district · 2 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.
Appellate journey
Relationships
Relies on Gulf Oil Corporation v. Gilbert · Fay v. Noia · Swift & Co. Packers v. Compania Colombiana Del Caribe, S. A. · National Equipment Rental, Ltd. v. Szukhent · Reetz v. Bozanich
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 68 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“allowing simultaneous prosecution of the same action in a foreign forum thousands of miles away would result in 'inequitable hardship' and 'tend to frustrate and delay the speedy and efficient determination of the cause'”
3 later decisions quote this exact passage · from the majority“In 1950 it was said of the few cases that enforced a forum clause, “they stand alone, separate and apart, branded with the malodorous antipathy of a bastard child at a family reunion of bluebloods.” Comment, Agreements in Advance Conferring Exclusive Jurisdiction on Foreign Courts, 10 La.L.Rev. 293, 297 (1950).”
2 later decisions quote this exact passage · from the concurrence“[whether the] foreign litigation ... would (1) frustrate a policy of the forum issuing the injunction; (2) be vexatious or oppressive; (3) threaten the issuing court’s in rem or quasi in rem jurisdiction; or (4) where the proceedings prejudice other equitable considerations'.”
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.