Société Nationale Industrielle Aérospatiale v. United States District Court for the Southern District of Iowa’s Empirical Analysis
1987
Citation profile
145 federal appellate · 120 district · 103 state decisions
How this case has been cited
Cited by 802 later decisions (34 by the Supreme Court) — most recently March 2025 · most notably Hartford Fire Insurance Co v. California Merrett Underwriting Agency Management Limited (1993), Anschuetz & Co. v. Mississippi River Bridge Authority (1987)
145 federal appellate · 120 district · 103 state decisions — followed in 20 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
reviewedIn re Societe Nationale Industrielle Aerospatiale (from Eighth Circuit Court of Appeals)
Relationships
Applies 28 U.S.C. § 1781 · 28 U.S.C. § 636
Relies on Hickman v. Taylor · Mitsubishi Motors Corporation v. Soler Chrysler-Plymouth Inc Soler Chrysler-Plymouth Inc · M/s Bremen v. Zapata off-Shore Company · Kerr v. United States Dist. Court for Northern Dist. of Cal. · Scherk v. Alberto-Culver Co.
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 802 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Comity refers to the spirit of cooperation in which a domestic tribunal approaches the resolution of cases touching the laws and interests of other sovereign states.”
66 later decisions quote this exact passage · from the concurrence“[W]e have long recognized the demands of comity in suits involving foreign states, either as parties or as sovereigns with a coordinate interest in the litigation.”
19 later decisions quote this exact passage · from the majority“decline[d] to hold as a blanket matter that comity requires resort to Hague Evidence Convention procedures without prior scrutiny in each case of the particular facts, sovereign interests, and likelihood that resort to those procedures will prove effective.”
8 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.