Folz v. State’s Empirical Analysis
1990
Citation profile
2 federal appellate · 32 district · 104 state decisions
How this case has been cited
Cited by 146 later decisions (2 by the Supreme Court) — most recently May 2022 · most notably Consolidated Rail Corporation v. Gottshall (1994), Clohessy v. Bachelor (1996)
2 federal appellate · 32 district · 104 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 Dillon v. Legg · 27 Cal. 3d 916 - Molien v. Kaiser Foundation Hospitals · Paugh v. Hanks · Payton v. Abbott Labs · Rodrigues v. State
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 146 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“1. There must be a marital, or intimate familial relationship between the victim and the plaintiff, limited to husband and wife, parent and child, grandparent and grandchild, brother and sister and to those persons who occupy a legitimate position in loco parentis; 2. The shock to the plaintiff must be severe, and result from a direct emotional impact upon the plaintiff caused by the contemporaneous sensory perception of the accident ...; 3. There must be some physical manifestation of, or physical injury to the plaintiff resulting from the emotional injury; 4. The accident must result in physical injury or death to the victim.”
3 later decisions quote this exact passage“a tort against the integrity of the family unit.”
3 later decisions quote this exact passage“[T]o establish the genuineness of a claim for negligent infliction of emotional distress, it is sufficient to allege and prove that (1) the plaintiff and the victim enjoyed a marital or intimate family relationship, (2) the plaintiff suffered severe shock from the contemporaneous sensory perception of the accident, and (3) the accident caused physical injury or death to the victim.”
2 later decisions 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.