Fitzgerald v. Congleton’s Empirical Analysis
1990
Citation profile
22 district · 65 state decisions
How this case has been cited
Cited by 87 later decisions — most recently June 2025 · most notably Baker v. State (1999), Bull v. Pinkham Engineering Assocs., Inc. (2000)
22 district · 65 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 6 Cal. 3d 176 - Neel v. Magana, Olney, Levy, Cathcart & Gelfand · Liberles v. County of Cook · Reed v. Real Detective Publishing Co. · State v. Jewett · Pancake House, Inc. v. Redmond Ex Rel. Redmond
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 87 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“By this statement, we do not necessarily foreclose the possibility of allowing for emotional-distress damages absent physical manifestations under special circumstances where the nature of the tortious act guarantees the genuineness of the claim. See W. Keeton, Prosser and Keeton on Torts § 54, at 362 (5th ed. 1984) (discusses actions for negligent transmission of a message, especially one announcing death, and negligent mishandling of corpses).”
1 later decision quote this exact passagee.g. Vincent v. DeVries“Actions for the following causes shall be commenced within three years after the cause of action accrues, and not after: (1) Assault and battery; (2) False imprisonment; (3) Slander and libel; (4) Except as otherwise provided in this chapter, injuries to the person suffered by the act or default of another person, ...; (5) Damage to personal property suffered by the act or default or another.”
1 later decision quote this exact passage“A civil action, except one brought upon the judgment or decree of a court of record of the United States or of this or some other state, except as otherwise provided, shall be commenced within six years after the cause of action accrues and not hereafter.”
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.