Cruise v. Castleton, Inc.’s Empirical Analysis
1978
Citation profile
4 federal appellate · 5 district · 3 state decisions
How this case has been cited
Cited by 25 later decisions — most recently March 2023 · most notably 466 F. Supp. 71 - Full-Sight Contact Lens Corp. v. Soft Lenses, Inc. (1978), United States Trotting Ass'n v. Chicago Downs Ass'n (1981)
4 federal appellate · 5 district · 3 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. § 1391 · 28 U.S.C. § 1404
Relies on Klaxon Co. v. Stentor Electric Manufacturing Co. · M/s Bremen v. Zapata off-Shore Company · Babcock v. Jackson · In-Flight Devices Corp. v. Van Dusen Air, Inc. · Durley v. Mayo
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Plaintiffs assert that the USTA has successfully achieved its goal of regulating the entire harness racing industry, and that by virtue of its control of the sport, membership in the USTA is, practically speaking, compulsory for all who wish to compete in the United States and Canada. Thus, plaintiffs argue, the forum clause is in reality part of a “contract of adhesion” to which they did not freely assent. But, even assuming the accuracy of their description of the USTA’s power, plaintiffs’ contention that the by-law is thus unenforceable as a matter of contract law * * * cannot be accepted. This is not a situation where the court is asked to enforce a highly prejudicial term in a contract between two parties of significantly different bargaining power, which term is to the benefit of the stronger and the detriment of the weaker. Plaintiffs have entered into a contract with their fellow members, who adopted the instant by-law for their mutual benefit. Collectively, they retain the power to change it. Cases concerning overwhelming bargaining power in a commercial context are simply inapposite. Moreover, plaintiffs’ argument proves too much, for it would vitiate every by-law of a host of membership associations.”
2 later decisions quote this exact passage · from the majority““It is far from clear, however, whether a court sitting in diversity should follow the Bremen approach towards forum-selection clauses or whether, by virtue of the Erie doctrine, it must apply state law on this question. The issue is a complex one, Matthiesssen v. National Trailer Convoy, Inc., 294 F.Supp. 1132, 1143, n. 3 (D.Minn.1968), about which ‘it would probably be possible to write at length ... ’ Geiger v. Keilani, 270 F.Supp. 761, 765 (E.D.Mich.1967).” Cruise v. Castleton, Inc., 449 F.Supp. 564 (S.D.N.Y.1978).”
1 later decision 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.