Zutter v. O'Connell’s Empirical Analysis
1930
Citation profile
1 district · 24 state decisions
How this case has been cited
Cited by 26 later decisions — most recently February 1969 · most notably Kennedy v. Camp (1954), Walker v. Kroger Grocery & Baking Co. (1934)
1 district · 24 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 Wick v. Wick · Glatz v. Kroeger Bros. · Sattler v. Niederkorn
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Although the verdict established the fact that the accident was the result of the concurring negligence of both Thomas O’Connell and Phillip Zutter, the right of contribution does not spring from concurring negligence. A common liability is the first essential for contribution. . . . In the absence of a common liability there can be no con tribution. Although the negligence of Phillip Zutter concurred to produce the injuries suffered by Donald Zutter, his son, it gave rise to no liability on the part of Phillip Zutter. Thomas O’Connell, therefore, if and when he paid the judgment, discharged no part of Phillip Zutter’s liability, which must be the basis of a right to contribution from Phillip Zutter. His cross-complaint was properly dismissed.””
2 later decisions 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.