V. T. A., Inc. v. Airco, Inc.’s Empirical Analysis
Citation profile
3 federal appellate · 16 district · 20 state decisions
How this case has been cited
Cited by 76 later decisions — most recently January 2026 · most notably Monterey Development Corporation v. Lawyer's Title Insurance Corporation (1993), Orner v. Shalala (1994)
3 federal appellate · 16 district · 20 state decisions — followed in 12 states
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 Browder v. Director Department of Corrections of Illinois · Chicot County Drainage District v. Baxter State Bank · Davis v. Alaska · Sears, Roebuck & Co. v. Stiffel Co. · Compco Corp. v. Day-Brite Lighting, Inc.
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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“For a judgment to be void under Rule 60(b)(4), it must be determined that the rendering court was powerless to enter it. If found at all, voidness usually arises for lack of subject matter jurisdiction ... or if the court has acted in a manner inconsistent with due process of law.”
4 later decisions quote this exact passage · from the majority“[I a judgment is void, it is a nullity from the outset and any 60(b)(4) motion for relief is therefore filed within a reasonable time.”
4 later decisions quote this exact passage · from the majority“[i]f voidness is found, relief is not a discretionary matter; it is mandatory.”
3 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.