Brown’s Empirical Analysis
Citation profile
6 district · 9 state decisions
How this case has been cited
Cited by 48 later decisions — most recently April 2025 · most notably In Re Merrill Lynch Trust Co. FSB (2007), 173 Cal. App. 4th 209 - Goldman v. KPMG, LLP (2009)
6 district · 9 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
Relies on Moses H. Cone Memorial Hospital v. Mercury Construction Corp. · Colorado River Water Conservation District v. United States · Mitsubishi Motors Corporation v. Soler Chrysler-Plymouth Inc Soler Chrysler-Plymouth Inc · Prima Paint Corp. v. Flood & Conklin Mfg. Co. · Green Tree Financial Corp.-Alabama v. Randolph
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 48 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) [Assumption by either state or federal court over a res; (2) relative inconvenience of the fora; (3) avoidance of piecemeal litigation; (4) order in which jurisdiction was obtained by the concurrent fora; (5) extent federal law provides the rules of decision on the merits; and (6) adequacy of the state proceedings in protecting the rights of the party invoking federal jurisdiction.”
3 later decisions quote this exact passage · from the majority“(1) the extent to which .a judgment rendered in the person’s absence might prejudice that person or the existing parties: (2) the extent to which any prejudice could be lessened or avoided by: (A) protective provisions in the judgment; (B) shaping the relief; or (C) other measures; (3) whether a judgment rendered in the person’s absence would be adequate; and (4) whether the plaintiff would have an adequate remedy if the action were dismissed for nonjoinder.”
1 later decision quote this exact passage · from the majority“The court must first determine whether the parties agreed to arbitrate the dispute. This determination involves two considerations: (1) whether there is a valid agreement to arbitrate between the parties; and (2) whether the dispute in question falls within the scope of that arbitration agreement. The court then must determine if any legal constraints foreclose arbitration of those claims.”
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.