Briggs v. Goodwin’s Empirical Analysis
569 F.2d 1 · 1977
Citation profile
29 federal appellate · 15 district ·
How this case has been cited
Cited by 60 later decisions (2 by the Supreme Court) — most recently March 2019 · most notably Stafford v. Briggs (1980), Briggs v. Goodwin (1977)
29 federal appellate · 15 district ·
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 28 U.S.C. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 1361 · 28 U.S.C. § 1391 · 28 U.S.C. § 1404 · 42 U.S.C. § 1985
Relies on International Shoe Co. v. Washington · Mullane v. Central Hanover Bank & Trust Co. · Hanson v. Denckla · McGee v. International Life Insurance · Hanna v. Plumer
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Nor do we perceive any constitutional problem in the statute as applied to this case. Appellees pitch their constitutional argument on their supposed lack of minimum contacts with the District of Columbia, resting on cases holding “that the Due Process Clause of the Fourteenth Amendment places some limit on the power of state courts to enter binding judgments against persons not served with process within their boundaries.” To the extent that this position presupposes that Congress’ constitutional authority to provide for the sound operation of the federal judicial system is limited by the same constraints that apply to extraterritorial service by state tribunals, it builds on sandy soil indeed. Whether or not Article III mandated the creation of any inferior federal courts at all, it is a matter of general agreement that the discretion of Congress “as to the number, the character, (and) the territorial limits” of the inferior federal courts is not limited by the Constitution. Congress might have established only one such court, or a mere handful; in that event, nationwide service would have been a practical necessity clearly consonant with the Constitution. That it was considered expedient to establish federal judicial districts in harmony with state boundaries did not alter the scope of legislative discretion in this regard, and in fact Congress has, on occasion, provided for nationwide service. While several cases have asserted apodietically that service outside a federal ”
2 later decisions quote this exact passage · from the majority“The summons and complaint in such an action shall be served as provided by the Federal Rules of Civil Procedure except that the delivery of the summons and complaint to the officer or agency as required by the rules may be made by certified mail beyond the territorial limits of the district in which the action is brought.”
1 later decision quote this exact passage · from the majoritye.g. Stafford v. Briggs“If, as appellees melodramatically contend, application of Section 1391(e) as written 'would subvert the orderly administration of the criminal justice system', it is Congress that should be alerted, for we are not at liberty to act in its stead”
1 later decision quote this exact passage · from the majoritye.g. Carter v. Clark
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.