Heckert v. Patrick’s Empirical Analysis
1984
Citation profile
133 state decisions
How this case has been cited
Cited by 133 later decisions — most recently March 2026 · most notably Manufacturer's National Bank v. Erie County Road Commission (1992), Pelletier v. Campbell (Slip Opinion) (2018)
133 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 Zents v. Board of Commissioners · 60 Wash. 2d 745 - Albin v. National Bank of Commerce · Carver v. Salt River Valley Water Users' Ass'n · 92 Ohio App. 14 - Hay v. Norwalk Lodge, B.P.O.E. · Strunk v. Dayton Power & Light Co.
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 133 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Where negligence revolves around the existence of a hazard or defect, a duty of reasonable care does not arise unless the defendant has notice, either actual or constructive, of such hazard or defect.”
8 later decisions quote this exact passage““A review of case law decided under R.C. 305.12 and its predecessor, G.C. 2408, reveals two recognized principles. First, the intent of the General Assembly was to place a duty on the commissioners only in matters concerning either the deterioration or disassembly of county roads and bridges. * * * Second, liability will not be imposed under the purview of the statute when the obstructions or interferences are unrelated to the conditions of the roadway. * * * “While it is clear that the commissioners do not have a statutory duty pursuant to R.C. 305.12 to trim or remove tree limbs which overhang a county road, appellants focus attention on cases decided under R.C. 723.01 in an effort to place liability on the commissioners. These cases, however, are not applicable here. R.C. 723.01 contains the language ‘and free from nui sanee, ’ which has been interpreted by this court to include more than just conditions of the roadway. The failure of the General Assembly to place this language in R.C. 305.12 clearly indicates its intention not to impose liability on the commissioners in matters unrelated to actual roadway conditions.” (Citations omitted and emphasis added.) Id. at 406-407 , 15 OBR at 520, 473 N.E.2d at 1208-1209 .”
4 later decisions quote this exact passage“matters unrelated to actual roadway conditions,”
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.