Goya Foods, Inc. v. Tropicana Products, Inc.’s Empirical Analysis
846 F.2d 848 · 1988
Citation profile
23 federal appellate · 12 district · 3 state decisions
How this case has been cited
Cited by 80 later decisions — most recently October 2022 · most notably Aktieselskabet Af 21. November 2001 v. Fame Jeans Inc. (2008), Sterling Drug, Inc. v. Bayer AG (1994)
23 federal appellate · 12 district · 3 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. § 1052 (§ 2 of the Trademark Act of 1946 (Lanham Act)) · 15 U.S.C. § 1057 (§ 7 of the Trademark Act of 1946 (Lanham Act)) · 15 U.S.C. § 1058 (§ 8 of the Trademark Act of 1946 (Lanham Act)) · 15 U.S.C. § 1062 (§ 12 of the Trademark Act of 1946 (Lanham Act)) · 15 U.S.C. § 1063 (§ 13 of the Trademark Act of 1946 (Lanham Act)) · 15 U.S.C. § 1067 (§ 17 of the Trademark Act of 1946 (Lanham Act)) · 15 U.S.C. § 1071 (§ 21 of the Trademark Act of 1946 (Lanham Act))
Relies on United States v. Western Pacific Railroad · Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc. · Texas Pacific Railway Company v. Abilene Cotton Oil Company · Glidden Company v. Zdanok Et Al. · Far East Conference v. United States
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 80 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“An examination of the cases illustrates the relatively narrow scope of the doctrine of primary jurisdiction. The doctrine has been applied only when a lawsuit raises an issue, frequently the validity of a commercial rate or practice, committed by Congress in the first instance to an agency’s determination, particularly when the issue involves technical questions of fact uniquely within the expertise and experience of an agency.”
7 later decisions quote this exact passage · from the majority“application of the doctrine has been refused when the issue at stake is legal in nature and lies within the traditional realm of judicial competence”
3 later decisions quote this exact passage · from the majority“[i]f a district court action involves only the issue of whether a mark is entitled to registration and if subject matter jurisdiction is available, the doctrine of primary jurisdiction might well be applicable, despite the differences between the trademark registration scheme and other regulatory patterns. In such a case, the benefits of awaiting the decision of the [Patent and Trademark Office (“PTO”) ] would rarely, if ever, be outweighed by the litigants’ need for prompt adjudication. But where, as in the pending case, a district court suit concerns infringement, the interest in prompt adjudication far outweighs the value of having the views of the PTO. Whether a litigant is seeking to halt an alleged infringement or, as in this case, seeking a declaration of non-infringement, it is entitled to have the infringement issue resolved promptly so that it may conduct its business affairs in accordance with the court’s determination of its rights. Delaying consideration of Goya’s claim pending the outcome of the TTAB proceedings undercuts the purpose of declaratory relief by forcing Goya either to abandon use of trademarks it has used for more than a decade or to persist in piling up potential damages.”
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.