No. 84-5811’s Empirical Analysis
1985
Citation profile
1 federal appellate · 9 district · 2 state decisions
How this case has been cited
Cited by 61 later decisions — most recently January 2018 · most notably Dainippon Screen Manufacturing Co. v. CFMT, Inc. (1998), Tri-State Generation and Transmission Association Inc v. Shoshone River Power Inc
1 federal appellate · 9 district · 2 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 Franchise Tax Board of the State of California v. Construction Laborers Vacation Trust for Southern California · Gully v. First Nat. Bank in Meridian · Shamrock Oil & Gas Corp. v. Sheets · Louisville & Nashville Railroad v. Mottley · Jones v. Rath Packing Co.
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.
“We have already discussed potential prejudice and the possibility of inadequate relief, two of the Rule 19(b) factors, in the analysis above. The remaining factor of Rule 19(b) deserving attention is the availability of an alternative forum. State court provides an adequate alternative forum. In state court, all the parties who should be joined, can be joined. And, unlike a case brought under the federal court’s original jurisdiction, the state court is the forum originally chosen by the plaintiffs. The availability of an alternative forum weighs strongly in favor of remanding this case. This ease is still young; discovery apparently has just begun. There would be little duplication of effort if this case were to return to the state court____ On the other hand, judicial efficiency would not be promoted by permitting this case to go forward in federal court, with the possibility that future litigation between plaintiffs and Microdata or between Microdata and Northwestern may be required to settle this controversy fully.”
1 later decision quote this exact passage · from the dissent“If a person as described in subdivision (a)(l)-(2) hereof cannot be made a party, the court shall determine whether in equity and good conscience the action should proceed among the parties before it, or should be dismissed, the absent person being thus regarded as indispensable. The factors to be considered by the court include: first, to what extent a judgment rendered in the person’s absence might be prejudicial to him or those already parties; second, the extent to which, by protective provisions in the judgment, by the shaping of relief, or other measures, the prejudice can be lessened or avoided; third, whether a judgment rendered in the person’s absence will be adequate; fourth, whether the plaintiff will have an adequate remedy if the action is dismissed for nonjoinder.”
1 later decision quote this exact passage · from the dissent“(A) in that person’s absence, the court cannot accord complete relief among existing parties; or (B) that person claims an interest relating to the subject of the action and is so situated that disposing of the action in the person’s absence may: (i) as a practical matter impair or impede the person’s ability to protect the interest; or (ii) leave an existing party subject to a substantial risk of incurring double, multi-pie, or otherwise inconsistent obligations because of the interest.”
1 later decision quote this exact passage · from the dissent
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.