103 N.J. Super. 127 - Hill v. MacOmber’s Empirical Analysis
1968
Citation profile
3 federal appellate · 2 district · 18 state decisions
How this case has been cited
Cited by 25 later decisions — most recently January 2004 · most notably United States Court of Appeals, Third Circuit (1976), Huddell v. Levin (1976)
3 federal appellate · 2 district · 18 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 Maddux v. Donaldson · Melone v. Jersey Central Power & Light Co. · Holtz v. Holder · Matthews v. Delaware, Lackawanna & Western Railroad · Ristan v. Frantzen
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Although concurrent tortfeasors generally are not jointly and severally liable where their acts caused distinct and separate injuries, or where some reasonable means of apportioning the damages is evident, the negligent driver of the automobile in the successive impact has been held jointly and severally liable for all of plaintiff’s injuries, if the injuries are “indivisible” and the liability therefor cannot be allocated with reasonable certainty to the successive collisions. This has come to be known as the “single, indivisible injury” rule. For some cases in which it was applied, see Maddux v. Donaldson, 362 Mich. 425 , 108 N.W.2d 33 , 100 A.L.R.2d 1 (Sup.Ct.1961); Holtz v. Holder, 101 Ariz. 247 , 418 P.2d 584 (Sup.Ct.1966); Berryman v. People’s Motor Bus Co., 228 Mo.App. 1032 , 54 S.W.2d 747 (CtApp.1932); Brantley v. Couch, 383 S.W.2d 307 (Mo.Ct.App.1964). In these days of chain collisions, it is better that a plaintiff, injured through no fault of his own, should be compensated by both tortfeasors, even though one of them may pay more than his theoretical share of the damage which his wrong has helped to create, than that the injured party have no recovery. Our courts have seemingly favored this more modern policy. See Ristan v. Frantzen, 14 N.J. 455 , 102 A.2d 614 (1954) and Matthews v. Delaware, L. & W.R.R. Co., 56 N.J.L. 34 , 27 A. 919 , 22 L.R.A. 261 (Sup. Ct.1893).”
2 later decisions quote this exact passage · from the majority“§ 433A. Apportionment of Harm to Causes (1) Damages for harm are to be apportioned among two or more causes where (a) there are distinct harms, or (b) there is a reasonable basis for determining the contribution of each cause to a single harm. (2) Damages for any other harm cannot be apportioned among two or more causes.”
1 later decision quote this exact passage · from the majority“In these days of chain collisions, it is better that a plaintiff, injured through no fault of his own, should be compensated by both tortfeasors, even though one of them may pay more than his theoretical share of the damage which his wrong has helped to create, than that the injured party have no recovery.”
1 later decision quote this exact passage · from the majoritye.g. Huddell v. Levin
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.