16 Wash. App. 893 - Fox v. Groff’s Empirical Analysis
1977
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently September 2024
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 83 Wash. 2d 764 - Curtis Lumber Co. v. Sortor · 75 Wash. 2d 808 - Summerrise v. Stephens · City Sash & Door Co. v. Bunn · 82 Wash. 2d 771 - Seamans v. Walgren · Dolan v. Baldridge
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.
“For the purpose of tolling any statute of limitations an action shall be deemed commenced when the complaint is filed or summons is served whichever occurs first. If service has not been had on the defendant prior to the filing of the complaint, the plaintiff shall cause one or more of the defendants to be served personally, or commence service by publication within ninety days from the date of filing the complaint. If the action is commenced by service on one or more of the defendants or by publication, the plaintiff shall file the summons and complaint within ninety days from the date of service. If following service, the complaint is not so filed, or following filing, service is not so made, the action shall be deemed to not have been commenced for purposes of tolling the statute of limitations.”
4 later decisions quote this exact passage“[i]f within the next 90 days [after filing] the defendants had been served, either personally or through the Secretary of State (RCW 46.64.040), the action would have been properly commenced and the statute of limitations would have been tolled.”
1 later decision quote this exact passagee.g. Martin v. Triol“The plaintiff had 90 days after filing his action, which did toll the running of the statute of limitations for that period of time, to serve the Secretary of State pursuant to RCW 46.64.040 or to obtain personal service upon the defendants.”
1 later decision quote this exact passagee.g. Martin v. Triol
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.