Gates’s Empirical Analysis
Citation profile
5 district · 1 state decisions
How this case has been cited
Cited by 30 later decisions — most recently April 2025 · most notably Gary B. Filler, Trustee of the Tra Rights Trust and Lawrence Perlman, Trustee of the Tra Rights Trust v. Hanvit Bank and Chohung Bank, Shinhan Bank, Janet Baker, James Baker, Jkbaker, Llc, and Jmbaker, LLC v. Hanvit Bank and Chohung Bank, Shinhan Bank (2004), Hyatt Corp. v. Stanton (1996)
5 district · 1 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 Cities of Charlottesville v. Official Committee of Unsecured Creditors of Columbia Gas Transmission Corp. · First National City Bank v. Banco Para El Comercio Exterior De Cuba · Saudi Arabia v. Nelson · Anschuetz & Co. v. Mississippi River Bridge Authority · Taylor v. Standard Gas & Electric 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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“As it is written, the Act provides potential immunity to entities that are either organs of a foreign state or political subdivision thereof or have a majority of shares owned by the foreign state or political subdivision. To add to that list entities that are owned by an agency or instrumentality would expand the potential immunity considerably because it would provide potential immunity for every subsidiary in a corporate chain, no matter how far down the line, so long as the first corporation is an organ of the foreign state or political subdivision or has a majority of its shares owned by the foreign state or political subdivision. Although such a broad view of sovereign immunity may very well be desirable, we cannot assume that Congress intended such a result when a literal reading of the statute leads to the opposite conclusion.”
3 later decisions quote this exact passage · from the majority“foreign state ... includes a political subdivision of a foreign state or an agency or instrumentality of a foreign state....”
3 later decisions quote this exact passage · from the majority“an entity - (1) which is a separate legal person, corporate or otherwise, and (2) which is an organ of a foreign state or political subdivision thereof, or a majority of whose shares or other ownership interest is owned by a foreign state or political subdivision thereof, and (3) which is neither a citizen of a State of the United States as defined in section 1332(c) and (d) of this title, nor created under the laws of any third country.”
2 later decisions quote this exact passage · from the majoritye.g. 57 F. Supp. 2d 863 - Morgan Equipment Co. v. Novokrivorogsky State Ore Mining & Processing Enterprise · Gary B. Filler, Trustee of the Tra Rights Trust and Lawrence Perlman, Trustee of the Tra Rights Trust v. Hanvit Bank and Chohung Bank, Shinhan Bank, Janet Baker, James Baker, Jkbaker, Llc, and Jmbaker, LLC v. Hanvit Bank and Chohung Bank, Shinhan Bank
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.