116 Ohio App. 3d 61 - Burgess v. Doe’s Empirical Analysis
1996
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently November 2025
14 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 Mitseff v. Wheeler · Commerce & Industry Insurance v. City of Toledo · Sawicki v. Village of Ottawa Hills · 20 Ohio App. 3d 132 - Clemets v. Heston · Saunders v. Choi
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“1) an assumption by the municipality, through promises or actions, of an affirmative duty to act on behalf of the party who was injured; 2) knowledge on the part of the municipality's agents that inaction could lead to harm; 3) some form of direct contact between the municipality's agents and the injured party; and 4) that party's justifiable reliance on the municipality's affirmative undertaking.”
1 later decision quote this exact passage“It is well established that no special relationship exists simply because a member of the general public requests assistance from the police.”
1 later decision quote this exact passage“If a special relationship is demonstrated, then a duty is established, and inquiry will continue into the remaining negligence elements.”
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.