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← 1997 SD 97 - Stratmeyer v. Stratmeyer

Stratmeyer v. Stratmeyer’s Empirical Analysis

1997

Citation profile

34
cited by 34 later decisions
2
states following
March 2023
most recently cited

5 district · 25 state decisions

How this case has been cited

Cited by 34 later decisions — most recently March 2023 · most notably Frank Martinelli Bridgeport Roman Catholic Diocesan Corporation (1999), Strassburg v. Citizens State Bank (1998)

5 district · 25 state decisions

1201997200020102020decided

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 Henslee v. Union Planters National Bank & Trust Co. · 142 Wis. 2d 257 - Hammer v. Hammer · 114 Wash. 2d 42 - Howell v. Spokane & Inland Empire Blood Bank · Isaac v. State Farm Mutual Automobile Insurance Co. · US West Communications, Inc. v. Public Utilities Commission

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 34 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “Any civil action based on intentional conduct brought by any person for recovery of damages for injury suffered as a result of childhood sexual abuse shall be commenced within three years of the act alleged to have caused the injury or condition, or three years of the time the victim discovered or reasonably should have discovered that the injury or condition was caused by the act, whichever period expires later.”
    3 later decisions quote this exact passage · from the concurrence
  2. “Sexual abuse at an early age prompts involuntary coping mechanisms which may prevent victims from making the causal connection between the abuse they suffered as children and the psychological problems they experience as adults. [A] cause of action does not necessarily accrue when the first manifestations of injury occur. The claimant has leeway to not start an action until she knows more about the injury and its probable cause. The policy justification for applying the statute of limitations to protect defendants from the threat of liability for deeds in the past is unpersuasive in incestuous abuse cases.... Further, the injustice of barring meritorious claims before the claimant knows of the injury outweighs the threat of stale or fraudulent actions.”
    2 later decisions quote this exact passage · from the concurrence
  3. “Imagine being pricked on the arm with a pin. At first, such an intrusion would be disturbing, but with time might seem uneventful. Now imagine the pin carried a dreaded affliction, only discoverable after years of incubation. Such is often the nature of childhood sexual abuse. Many children only realize years later the true significance of the abuse they endured, especially in cases where the molestation occurred at the hands of family members or other trusted individuals. For some children, sexual violation is so traumatic it becomes psychologically self-concealing, if only to preserve sanity. For this reason, our Legislature enacted SDCL 26-10-25 creating a discovery rule for adult survivors of child sex abuse.”
    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.