Zeiler v. Deitsch’s Empirical Analysis
500 F.3d 157 · 2007
Citation profile
4 federal appellate · 7 district · 6 state decisions
How this case has been cited
Cited by 53 later decisions — most recently July 2025 · most notably Scandinavian Reinsurance Co. v. Saint Paul Fire & Marine Insurance (2012), Telenor Mobile Communications AS v. Storm LLC (2009)
4 federal appellate · 7 district · 6 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 9 U.S.C. § 10 (Federal Arbitration Act) · 9 U.S.C. § 202 · 9 U.S.C. § 207
Relies on Volt Information Sciences Inc v. Board of Trustees of Leland Stanford Junior University · Yusuf Ahmed Alghanim & Sons, W.L.L. v. Toys "R" Us, Inc. · Duferco International Steel Trading v. T. Klaveness Shipping A/S · Seetransport Wiking Trader Schiffarhtsgesellschaft MBH & Co. v. Navimpex Centrala Navala · National Market Share, Inc. v. Sterling National Bank
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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“1. Recognition and enforcement of the award may be refused, at the request of the party against whom it is invoked, only if that party furnishes to the competent authority where the recognition and enforcement is sought, proof that: (a) The parties to the agreement referred to in article II were, under the law applicable to them, under some incapacity, or the said agreement is not valid under the law to which the parties have subjected it or, failing any indication thereon, under the law of the country where the award was made; or (b) The party against whom the award is invoked was not given proper notice of the appointment of the arbitrator or of the arbitration proceedings or was otherwise unable to present his case;' or (c) The award deals with a difference not contemplated by or not falling within the terms of the submission to arbitration, or it contains decisions on matters beyond the scope of the submission to arbitration, provided that, if the decisions on matters submitted to arbitration can be separated from those not so submitted, that part of the award which contains decisions on matters submitted to arbitration may be recognized and enforced; or (d) The composition of the arbitral authority or the arbitral procedure was not in accordance with the agreement of the parties, or, failing such agree-ment, was not in accordance with the law of the country where the arbitration took place; or (e) The award has not yet become binding on the parties, or has been set aside”
3 later decisions quote this exact passage · from the majority“Confirmation under the Convention is a summary proceeding in nature, which is not intended to involve complex factual determinations, other than a determination of the limited statutory conditions for confirmation or grounds for refusal to confirm.”
2 later decisions quote this exact passage · from the majority“[T]he showing required to avoid summary confirmation is high.”
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.