Friedman’s Empirical Analysis
Citation profile
11 federal appellate · 8 district · 1 state decisions
How this case has been cited
Cited by 92 later decisions — most recently March 2019 · most notably Graham-Humphreys v. Memphis Brooks Museum of Art, Inc. (2000), Collyer v. Darling (1996)
11 federal appellate · 8 district · 1 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 Kulko v. Superior Court of California in and for City and County of San Francisco · Owens v. Okure · Omni Capital International, Ltd. v. Rudolf Wolff & Co. · Wood v. Carpenter · Pinney Dock & Transport Co. v. Penn Central Corp.
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 92 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If a service of the summons and complaint is not made upon a defendant within 120 days after the filing of the complaint and the party on whose behalf such service was required cannot show good cause why such service was not made within that period, the action shall be dismissed as to that defendant without prejudice upon the court’s own initiative with notice to such party or upon motion.”
4 later decisions quote this exact passage“(1) wrongful concealment of their actions by the defendants; (2) failure of the plaintiff to discover the operative facts that are the basis of his cause of action within the limitations period; and (3) plaintiffs due diligence until discovery of the facts.”
2 later decisions quote this exact passage“The “[ljegislative history [to Rule 4(j) 11 ] provides only one example where an extension for good cause is appropriate — when the defendant intentionally evades service of process.” Inadvertent failure or half-hearted efforts to serve process on a defendant within the time allowed do not constitute good cause. Diligence and reasonable efforts to serve process may demonstrate good cause under the rule. ... A showing of good cause under the rule must relate to the reasons why service of process was not made in a timely manner, not to other reasons why a civil action or adversary proceeding should not be dismissed. “Good cause” does not mean merely that the defendant was not prejudiced by the late service of process.”
1 later decision quote this exact passage
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.