Puerto Rico v. SS Zoe Colocotroni’s Empirical Analysis
628 F.2d 652 · 1980
Citation profile
41 federal appellate · 39 district · 19 state decisions
How this case has been cited
Cited by 125 later decisions (1 by the Supreme Court) — most recently July 2014 · most notably S.S. Zoe Colocotroni v. Puerto Rico (1981), Guardian Royal Exchange Assurance, Ltd. v. English China Clays, P.L.C. (1991)
41 federal appellate · 39 district · 19 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
Relies on International Shoe Co. v. Washington · World-Wide Volkswagen Corp. v. Woodson · Hanson v. Denckla · McGee v. International Life Insurance · Milliken v. Meyer
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 125 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“... an insurer such as West of England, has the power through its contracts of insurance meaningfully to influence the course taken by insured vessels. By limiting coverage to specified jurisdictions, West of England could be reasonably certain it would not be hailed into court in an undesired forum. In other words, an insurer is not at the mercy of the insured owner’s unilateral choice of destination in the same way a seller of chattels is at the mercy of the buyer.... Where, as here, the insurer has the means available to structure its primary conduct so as to control the area within which it will be subject to direct action, where it is undoubtedly aware that the objects of its policies are regularly present in a particular jurisdiction, and where it not only does not act to curtail such presence but actively promotes it by providing contractual services in the jurisdiction, we hold that such an insurer is amenable to personal jurisdiction in the forum.”
2 later decisions quote this exact passage · from the majority““To sustain in personam jurisdiction over a foreign corporation, the Court must find both that personal jurisdiction is authorized by the local statute and that the exercise of such jurisdiction does not violate the due process requirement that the nonresident defendant has certain ‘minimum contacts’ with the forum state.” Commonwealth of Puerto Rico v. SS Zoe Colocotroni, 628 F.2d 652, 667 (1st Cir. 1980) (Cases cited omitted).”
2 later decisions quote this exact passage · from the majority“[A]n insurer is not at the mercy of the insured owner's unilateral choice of destination in the same way a seller of chattels is at the mercy of the buyer.”
2 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.