State v. Hatfield’s Empirical Analysis
1951
Citation profile
6 federal appellate · 2 district · 111 state decisions
How this case has been cited
Cited by 123 later decisions — most recently July 2016 · most notably 5 Cal. 3d 153 - Vesely v. Sager (1971), Rappaport v. Nichols (1959)
6 federal appellate · 2 district · 111 state decisions — followed in 25 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 Thomas v. . Winchester · Bertholf v. . O'Reilly · Rounds, Admr. v. Phillips · Houlihan v. McCall · Freese v. Tripp
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 123 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““[T]he common law knows no right of action against a seller of intoxicating liquors, as such, for ‘causing’ intoxication of the person whose negligent or wilful wrong has caused injury. Human beings, drunk or sober, are responsible for their own torts. The law (apart from statute) recognizes no relation of proximate cause between a sale of liquor and a tort committed by a buyer who has drunk the liquor. * * * No case, English or American, has been cited, and we have found none, in which (apart from statute) a seller of intoxicating liquor has been held liable for a tort of the buyer who drank the liquor.” 78 A.2d at 756 .”
11 later decisions quote this exact passage · from the majority“"[W]e should virtually usurp legislative power if we should declare plaintiffs contentions to be the law of Maryland. In the course of the last hundred years there probably has seldom, if ever, (except during prohibition) been a regular session of the General Assembly at which no liquor laws were passed. On few subjects are legislators kept better informed of legislation in other states. In the face of the flood of civil damage laws enacted, amended and repealed in other states and the Volstead Act — and of the total absence of authority for such liability, apart from statute — the fact that there is now no such law in Maryland expresses the legislative intent as clearly and compellingly as affirmative legislation would.” Id. at 256 .”
2 later decisions quote this exact passage · from the majority“Apart from statute, the common law knows no right of action against a seller of intoxicating liquors, as such, for “causing” the intoxication of the person whose negligence or wilful wrong has caused injury. Human beings, drunk or sober, are responsible for their own torts. The law (apart from statute) recognizes no relation of proximate cause between the sale of liquor and a tort committed by a buyer who has drunk the liquor. * * * The common-law rule holds the man who drank the liquor liable, and considers the act of selling it as too remote to be a proximate cause of an injury caused by the negligent act of the purchaser of the drink.”
2 later decisions quote this exact passage · from the majority
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.