Lake v. Lake’s Empirical Analysis
817 F.2d 1416 · 1987
Citation profile
66 federal appellate · 33 district · 6 state decisions
How this case has been cited
Cited by 166 later decisions — most recently April 2025 · most notably Schwarzenegger v. Fred Martin Motor Co. (2004), Bancroft & Masters, Inc. v. Augusta National Inc. (2000)
66 federal appellate · 33 district · 6 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 · Burger King Corporation v. Rudzewicz · World-Wide Volkswagen Corp. v. Woodson · Hanson v. Denckla · McGee v. International Life Insurance
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 166 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) The non-resident defendant must purposefully direct his activities or consummate some transaction with the forum or resident thereof; or perform some act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws; (2) the claim must be one which arises out of or relates to the defendant’s forum-related activities; and (3) the exercise of jurisdiction must comport with fair play and substantial justice, i.e. it must be reasonable.”
52 later decisions quote this exact passage · from the majority“(1) the burden on the defendant, (2) existence of an alternative forum, (3) convenient and effective relief for the plaintiff, (4) the forum state’s interest in adjudicating the suit, (5) efficient resolution of the controversy, (6) purposeful interjection, and (7) conflicts with sovereignty.”
4 later decisions quote this exact passage · from the majority“As we have previously recognized, Calder stands for the proposition that purposeful availment is satisfied even by a defendant “whose only ‘contact’ with the forum state is the ‘purposeful direction’ of a foreign act having effect in the forum state.” Based on these interpretations of Calder , the “effects” test requires that the defendant allegedly have (1) committed an intentional act, (2) expressly aimed at the forum state, (3) causing harm that the defendant knows is likely to be suffered in the forum state.”
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.