613 F. Supp. 1563 - Violet v. Picillo’s Empirical Analysis
1985
Citation profile
10 district · 5 state decisions
How this case has been cited
Cited by 25 later decisions — most recently December 2007 · most notably 682 F. Supp. 706 - O'NEIL v. Picillo (1988), In Re Acushnet River & New Bedford Harbor Proceedings Re Alleged PCB Pollution (1987)
10 district · 5 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 15 U.S.C. § 25 (§ 15 of the Clayton Antitrust Act of 1914) · 15 U.S.C. § 5 (§ 5 of the Sherman Antitrust Act) · 15 U.S.C. § 77V (§ 22 of the Securities Act of 1933) · 15 U.S.C. § 78A (§ 1 of the Securities Exchange Act of 1934) · 28 U.S.C. § 1335 · 28 U.S.C. § 1738 · 33 U.S.C. § 1251 (Alternative Water Sources Act of 2000) · 33 U.S.C. § 1321
Relies on International Shoe Co. v. Washington · World-Wide Volkswagen Corp. v. Woodson · Helicopteros Nacionales De Colombia, S. A. v. Hall · McGee v. International Life Insurance · Shaffer v. Heitner
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he federal statutes [which implied nationwide service of process] laid venue in only one district, such that a failure to imply authority for extraterritorial process would deprive any federal court of the power to adjudicate eases under the statute, absent the fortuitous circumstance that a defendant enjoyed the necessary minimum contacts with the sole district in which venue was proper. Violet v. Picillo, 613 F.Supp. 1563 (D.R.I. 1985).”
2 later decisions quote this exact passage“Significant among the pervasive industrial practices recognized by Congress is the problem of dumping wastes at improper, illegal or inappropriate sites, and the associated problem of “midnight,” or clandestine dumping of chemical wastes at abandoned, remote or Mdden locations. See, e.g., 1980 U.S.C.C. & A.N. at 6121-22 (describing various practices at selected sites); 126 Cong.Rec. S14,973 (daily ed. Nov. 24 1980) (remarks of Sen. Tsongas) (describing practices of “ ‘midnight dumpers’ who dispose of toxic chemicals and hazardous materials in quarries, in streams, in forests, or spread them on open roads ...”); id. at 14,973 (remarks of Sen. Ford). And, legislators recognized that the problem of “midnight dumping” frequently involves waste that is transported over state lines. See, e.g., 126 Cong.Rec. H9,461 (daily ed. Sept. 23, 1980) (remarks of Rep. Martin) (“because of the nature of clandestine dumping operations [a] State ... wMeh does not generate a large volume of toxic waste, has been victimized as a dumping ground for waste from other States); 126 Cong.Rec. Hll,798 (remarks of Rep. Edgar) (daily ed. Dec. 3, 1980) (“‘midnight dumpers’ [have] trucked wastes from all over the Eastern Seaboard and dumped them illegally at various sites through [Pennsylvania]); 126 Cong.Rec. H9,448 (remarks of Rep. LaFalce) (daily ed. Sept. 23, 1980) (noting interstate scope of problem). This unfortunate history attests to the existence of a vast, unmonitored secondary toxic disposal marke”
1 later decision quote this exact passage““[T]he key factors justifying a different jurisdictional rule are two-fold. First, unlike local merchants, such interstate distributors have an ‘interest in reaching as broad a market as’ possible [citation], and place their products into the stream of commerce with either the subjective intention [citation], or objective reason to know [citation], that their products will be sold ‘to a nation-wide market, that is, in any or all states’ [citation]. Thus, even if their ‘products were sold indirectly through importers or distributors with independent sales and marketing schemes’ [citation] * * * — independent parties whom the defendant distributors do not directly control [citation] — and even if their products are sold to an intermediary with ‘ “no indication whatsoever as to their ultimate destination” ’ [citation], the fact that these manufacturers or distributors place their products in a stream of commerce destined for sale through a broad interstate market, and reap the attendant benefits, renders them properly subject to suit in one of the states comprising that market. The second important distinguishing factor is that, unlike local merchants serving a self-circumscribed market, who ‘ordinarily [have] no control over where the buyer takes the product after it is sold’ [citation], parties operating on a broad interstate scale can act ‘to limit the states in which [their products will] be sold’ [citation], and can thereby protect themselves against suit in an undesired fo”
1 later decision quote this exact passage
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.