Eagerton v. Valuations, Inc.’s Empirical Analysis
698 F.2d 1115 · 1983
Citation profile
22 federal appellate ·
How this case has been cited
Cited by 39 later decisions — most recently May 2025 · most notably Cabalceta v. Standard Fruit Co. (1989), Hawthorne v. Mac Adjustment, Inc. (1998)
22 federal appellate ·
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 United Mine Workers of America v. Gibbs · Bonner v. City of Prichard · Ohio Bureau of Employment Services v. Hodory · Owen Equipment & Erection Co. v. Kroger · American Fire & Casualty Co. v. Finn
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Ancillary jurisdiction may only operate ‘when there is a right nexus with a subject matter properly in federal court’. This nexus or logical relationship between the main claim and the incidental state claim arises (1) when the same aggregate or operative facts serves as the basis for both claims or (2) when the core of facts supporting the original claim activate legal rights in favor of a party defendant that would otherwise remain dormant.”
4 later decisions quote this exact passage · from the majority“The application of ancillary jurisdiction was significantly expanded in Moore v. New York Cotton Exchange, 270 U.S. 593 , 46 S.Ct. 367 , 70 L.Ed. 750 (1926), when a federal court was allowed to adjudicate an ancillary compulsory counterclaim after the main federal antitrust claim was dismissed on the merits. The unification of law and equity which culminated with adoption of the Federal Rules of Civil Procedure also served to expand the use of incidental jurisdiction consistent with fairness to the parties. See United Mine Workers v. Gibbs, 383 U.S. 715, 724 , 86 S.Ct. 1130, 1137 , 16 L.Ed.2d 218 (1966). As a result, Rule 13 compulsory counterclaims and cross claims as well as Rule 14 impleader actions are almost always viewed as ancillary. See, e.g., Moore, supra (compulsory counterclaims); Scott v. Fancher, 369 F.2d 842 (5th Cir.1966) (cross-claims); Dery v. Wyer, 265 F.2d 804 (2d Cir.1959) (interpleader action).”
1 later decision quote this exact passage · from the majority“when there is a tight nexus with a subject matter properly in federal court.”
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.