Club Assistance Program, Inc. v. Zukerman’s Empirical Analysis
1984
Citation profile
12 federal appellate · 3 district · 6 state decisions
How this case has been cited
Cited by 61 later decisions — most recently March 2018 · most notably 141 Ill. 2d 244 - Rollins v. Ellwood (1990), Bally Export Corporation, a Delaware Corporation v. Balicar, Ltd., a Foreign Corporation, and Juliano Internacional S.A., a Foreign Corporation (1986)
12 federal appellate · 3 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 11 U.S.C. § 362 · 18 U.S.C. § 1962 (§ 901 of the Racketeer Influenced and Corrupt Organizations Act) · 28 U.S.C. § 1404 · 28 U.S.C. § 1406
Relies on International Shoe Co. v. Washington · United Mine Workers of America v. Gibbs · World-Wide Volkswagen Corp. v. Woodson · Shaffer v. Heitner · Calder v. Jones
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“But the consequences upon which [Continental Bank] reifies] are too remote from the misconduct of [defendants] to support the conclusion that the tortious acts complained of were committed in Illinois. The situs of the last event whose happening was necessary to hold [defendants] liable was in [Nebraska]. It was there that____ the misappropriation and conversion of the [Continental Bank’s funds] occurred____ The tortious acts, if any, and the losses or injury were complete when they occurred in [Nebraska]. That, therefore, was the place of the wrongs; their commission cannot reasonably or justifiably be transferred to Illinois by the rationale that their consequences reduced the amount of corporate assets in this State.”
3 later decisions quote this exact passage · from the majority“(g) Consolidation of Defenses in Motion. A party who makes a motion under this rule may join with it any other motions herein provided for and then available to the party. If a party makes a motion under this rule but omits therefrom any defense or objection then available to the party which this rule permits to be raised by motion, the party shall not thereafter make a motion based on the defense or objection so omitted, except a motion as provided in subdivision (h)(2) hereof [which is not applicable in this case] on any of the grounds there stated. (h) Waiver or Preservation of Certain Defenses. (1) A defense of lack of jurisdiction over the person, improper venue, insufficiency of process, or insufficiency of service of process is waived (A) if omitted from a motion in the circumstances described in subdivision (g)....”
1 later decision quote this exact passage · from the majority“Any business person — indeed anyone other than lawyers trained in spinning out the legal fictions that dominate so much of legal “reasoning” — would unquestionably view this as a California case. Defendants’ asserted Illinois contacts allegedly resulted only from their desire to preserve the ill-gotten gains they had already appropriated. And if in fact defendants did not loot Genesis, but only presided over a failed business, it is even more anomalous they would have to defend this action in Illinois.”
1 later decision 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.