Zirn v. Cullom’s Empirical Analysis
1946
Citation profile
4 federal appellate · 34 state decisions
How this case has been cited
Cited by 46 later decisions — most recently July 2003 · most notably 46 Cal. 2d 375 - Albertson v. Raboff (1956), CRIBERG v. Raymond (1976)
4 federal appellate · 34 state decisions — followed in 12 states
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 Moore v. Manufacturers' National Bank of Troy · People Ex Rel. Bensky v. Warden of the City Prison
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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It is not absolutely essential, in order to obtain the benefits of absolute privilege, that the language claimed to be defamatory be spoken in open court or contained in a pleading, brief, or affidavit. Thus, ‘the privilege extends to statements made to a solicitor when preparing the witness’s proof, and also to letters passing between a solicitor and his client, written for the purpose of giving or obtaining advice.’ Odgers, Libel and Slander, 6th Ed., p. 198. ‘The same privilege exists as to statements made to a party and his solicitor in preparing the proof for trial.’ Newell, Slander and Libel, 4th Ed., p. 401.” Id. at 440-41 .”
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.