Pennoyer v. Neff’s Empirical Analysis
95 U.S. 714 · 1877
Citation profile
640 federal appellate · 276 district · 2,561 state decisions
How this case has been cited
Cited by 4,660 later decisions (259 by the Supreme Court) — most recently November 2025 · most notably International Shoe Co. v. Washington (1945), Mullane v. Central Hanover Bank & Trust Co. (1950)
640 federal appellate · 276 district · 2,561 state decisions — followed in 50 states
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 Thompson v. Whitman · Cooper v. Reynolds · Lafayette Insurance v. French · Galpin v. Page
Cited together with International Shoe Co. v. Washington · Hanson v. Denckla · McGee v. International Life Insurance · Milliken v. Meyer · Shaffer v. Heitner
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 4,660 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The authority of every tribunal is necessarily restricted by the territorial limits of the State in which it is established.”
35 later decisions quote this exact passage · from the majority““In other words, such service may answer in all actions which are substantially proceedings in rein. But where the entire object of tbe action is to determine the personal rights and obligations of the defendants — that is, where the suit is merely in personam — constructive service in this form upon a non-resident is ineffectual for any purpose.” Pennoyer v. Neff, 95 U. S. 714 , 727 ( 24 L. Ed. 565 ).”
30 later decisions quote this exact passage · from the majority“"So the State, through its tribunals, may subject property situated within its limits owned by non-residents to the payment of the demands of its own citizens against them; and the exercise of this jurisdiction in no way infringes upon the sovereignty of the State where the owners are domiciled. Every State owes protection to its own citizens; and when non-residents deal with them, it is a legitimate and just exercise of authority to hold and appropriate any property owned by such non-residents to satisfy the claims of its citizens. It is in virtue of the State's jurisdiction over the property of the non-resident situated within its limits that its tribunals can inquire into that non-resident's obligations to its own citizens, and the inquiry can then be carried only to the extent necessary to control the disposition of the property. If the non-resident have no property in the State, there is nothing upon which the tribunals can adjudicate."”
13 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.