Pedzewick v. Foe’s Empirical Analysis
1997
Citation profile
4 federal appellate · 13 district ·
How this case has been cited
Cited by 21 later decisions — most recently February 2019
4 federal appellate · 13 district ·
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 28 U.S.C. § 1404 · 28 U.S.C. § 1406 · 28 U.S.C. § 1631
Relies on Erie Co v. Tompkins · Burnett v. New York Central Railroad · Goldlawr, Inc. v. Heiman · Order of Railroad Telegraphers v. Railway Express Agency, Inc. · Scott v. Rosenberg
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 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[w]henever a ... court finds that there is a want of jurisdiction, the court shall, if it is in the interest of justice, transfer such action ... to any other such court in which the action ... could have been brought at the time it was filed.”
2 later decisions quote this exact passage · from the majority“agree[ing] with the line of cases limiting section 1631 to transfer for lack of subject matter jurisdiction only”
2 later decisions quote this exact passage · from the majority“Striking the proper balance here is facilitated by the requirement that transfer is available under section 1406(a) only when it is in the interest of justice. In the context of personal jurisdiction, the interest of justice — at the very least— must mean that the plaintiff made a good faith mistake in believing that the court in which the action was filed had personal jurisdiction over the defendants .... [A] court ought deny transfer when a plaintiff fails to exercise proper diligence or does not act in good faith in deciding where to file suit. In this case, Pedzewick did not have a good faith belief that the Defendants were subject to personal jurisdiction in this Court. This is a Florida accident involving Georgia defendants. The only nexus to Massachusetts is Ped-zewick. This Court-finds nothing in the record to infer that Pedzewick could reasonably have believed that this Court had personal jurisdiction over the Defendants. Pedzewick should not benefit from her lack of diligence just because she filed her case in some court on the last day of the statute of limitations.”
1 later decision quote this exact passage · from the majoritye.g. In Re Pickeral
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.