Guthrie v. Carter’s Empirical Analysis
1950
Citation profile
2 federal appellate · 9 state decisions
How this case has been cited
Cited by 11 later decisions — most recently March 1970
2 federal appellate · 9 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 Richter v. Seawell · Green v. Smith · Arnold v. Wood · Chesapeake & Ohio Railway Co. v. Heath · Darden v. Murphy
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In such a case negligence cannot be presumed from the mere happening of the accident. The burden was on the plaintiff to prove that it was due to the negligence of the defendant as a proximate cause. What is proved must establish more than a probability of negligence. Inferences must be based on facts, not on presumptions. It was incumbent on the plaintiff to show why and how the accident happened. If that is left to conjecture, guess or random judgment, the plaintiff is not entitled to recover. Chesapeake, etc. Ry Co. Heath, 103 Va. 64 , 48 S.E. 508 ; Arnold Wood, 173 Va. 18 , 3 S.E.(2d) 374; Toler Yellow Cab Co., 179 Va. 38 , 18 S.E.(2d) 250; Richter Seawell, 183 Va. 379 , 32 S.E.(2d) 62.”
1 later decision quote this exact passage · from the majoritye.g. Tolbert v. Gillespie
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.