Combs’s Empirical Analysis
Citation profile
4 federal appellate · 45 district · 25 state decisions
How this case has been cited
Cited by 246 later decisions — most recently June 2025 · most notably Mylan Laboratories, Inc. v. Akzo, N.V. (1993), Celotex Corporation Owens-Illinois Incorporated v. Rapid American Corporation (1997)
4 federal appellate · 45 district · 25 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 Hj Inc v. Northwestern Bell Telephone Company · Dillon v. Numismatic Funding Corp. · Brandenburg v. Seidel · International Data Bank, Ltd. v. Zepkin · North Carolina v. Alexander & Alexander Services, Inc.
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 246 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]hen, as here, the court addresses the question [of personal jurisdiction] on the basis only of motion papers, supporting legal memoranda and the relevant allegations of a complaint, the burden on the plaintiff is simply to make a prima facie showing of a sufficient jurisdictional basis to survive the jurisdictional challenge.”
18 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.