Wachovia Bank, National Ass'n v. Schmidt’s Empirical Analysis
2006
Citation profile
138 federal appellate · 96 district · 21 state decisions
How this case has been cited
Cited by 571 later decisions (15 by the Supreme Court) — most recently June 2026 · most notably Burlington Northern & Santa Fe Railway Co. v. White (2006), 135 S. Ct. 1074 - Yates v. United States (2015)
138 federal appellate · 96 district · 21 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.
Appellate journey
reviewedWachovia Bank, National Ass'n v. Schmidt (from Fourth Circuit Court of Appeals)
Relationships
Applies 12 U.S.C. § 21A · 12 U.S.C. § 22 · 12 U.S.C. § 36 · 12 U.S.C. § 52 · 12 U.S.C. § 92 (§ 13 of the Federal Reserve Act of 1913) · 12 U.S.C. § 94 · 28 U.S.C. § 1332 (Class Action Fairness Act of 2005) · 28 U.S.C. § 1348
Relies on Heckler v. Ringer · Mansfield Ry Co v. Swan · Newman-Green, Inc. v. Alfonzo-Larrain · Neirbo Co. v. Bethlehem Shipbuilding Corp. · Leroy v. Great Western United Corp.
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 571 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“To achieve complete parity with state banks and other state-incorporated entities, a national banking association would have to be deemed a citizen of both the State of its main office and the State of its principal place of business. See Horton [v. Bank One, N.A], 387 F.3d [426], at 431, and n. 26 [ (5th Cir.2004) ]; Firstar Bank, N.A. [v. Faul ], 253 F.3d [982], at 993-994 [(7th Cir. 2001) ]. Congress has prescribed that a corporation “shall be deemed to be a citizen of any State by which it has been incorporated and of the State where it has its principal place of business.” 28 U.S.C. § 1332 (c)(1) (emphasis added). The counterpart provision for national banking associations, 1348, however, does not refer to “principal place of business”; it simply deems such associations “citizens of the States in which they are respectively located.” The absence of a “principal place of business” reference in § 1348 may be of scant practical significance for, in almost every case, as in this one, the location of a national bank’s main office and of its principal place of business coincide.”
7 later decisions quote this exact passage · from the concurrence“Subject-matter jurisdiction ... concerns a court's competence to adjudicate a particular category of cases”
7 later decisions quote this exact passage · from the majority““The district courts shall have original jurisdiction of any civil action commenced by the United States, or by direction of any officer thereof, against any national banking association, any civil action to wind up the affairs of any such association, and any action by a banking association established in the district for which the court is held, under chapter 2 of Title 12, to enjoin the Comptroller of the Currency, or any receiver acting under his direction, as provided by such chapter. All national banking associations shall, for the purposes of all other actions by or against them, be deemed citizens of the States in which they are respectively located.””
5 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.