Barrett v. Catacombs Press’s Empirical Analysis
1999
Citation profile
4 federal appellate · 8 district · 7 state decisions
How this case has been cited
Cited by 32 later decisions — most recently October 2015 · most notably Toys "R" Us, Inc. v. Step Two, S.A. (2003), Revell v. Lidov (2002)
4 federal appellate · 8 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
Applies 28 U.S.C. § 1332 (Class Action Fairness Act of 2005)
Relies on International Shoe Co. v. Washington · Burger King Corporation v. Rudzewicz · World-Wide Volkswagen Corp. v. Woodson · Hanson v. Denckla · Helicopteros Nacionales De Colombia, S. A. v. Hall
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he likelihood that personal jurisdiction can be constitutionally exercised is directly proportionate to the nature and quality of commercial activity that an entity conducts over the Internet. ... At one end of the spectrum are situations where a defendant clearly does business over the Internet. If the defendant enters into contracts with residents of a foreign jurisdiction that involve the knowing and repeated transmission of computer files over the Internet, personal jurisdiction is proper. At the opposite end are situations where a defendant has simply posted information on an Internet Web site which is accessible to users in foreign jurisdictions. A passive Web site that does little more than make information available to those who are interested in it is not grounds for the exercise [of] personal jurisdiction. The middle ground is occupied by interactive Web sites where a user can exchange information with the host computer. In these cases, the exercise of jurisdiction is determined by examining the level of interactivity and commercial nature of the exchange of information that occurs on the Web site.”
1 later decision quote this exact passage · from the majority“It is certainly foreseeable that some of the harm would be felt in [the forum state] because Plaintiff lives and works there, but such foreseeability is not sufficient for an assertion of jurisdiction. While we agree, that [forum] residents are among the recipients or viewers of such defamatory statements, they are but a fraction of other worldwide Internet users who have received or viewed such statements. The mere allegations that the Plaintiff feels the effect of the Defendant’s tortious conduct in the forum because the Plaintiff is located there is insufficient to satisfy Calder . Unless [the forum state] is deliberately or knowingly targeted by the tortfeasor, the fact that harm is felt in [the forum state] from conduct occurring outside [it] is never sufficient to satisfy due process.”
1 later decision quote this exact passage · from the majority“(1) The defendant committed an intentional tort; (2) The plaintiff felt the brunt of the harm in the forum such that the forum can be said to be the focal point of the harm suffered by the plaintiff as a result of that tort; [and] (3) The defendant expressly aimed his tortious conduct at the forum such that the forum can be said to be the focal point of the tortious activity[.]”
1 later decision quote this exact passage · from the majoritye.g. Gorman v. Jacobs
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.