Merriam v. Wanger’s Empirical Analysis
2000
Citation profile
3 federal appellate · 7 district · 14 state decisions
How this case has been cited
Cited by 26 later decisions — most recently February 2025 · most notably Samaan v. St. Joseph Hospital (2012), State v. Rabon (2007)
3 federal appellate · 7 district · 14 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 Wing v. Morse · Champagne v. Mid-Maine Medical Center · Webb v. Haas · Corey v. Norman, Hanson & DeTroy · Searles v. Trustees of St. Joseph's College
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.
“Evidence is sufficient to support a finding of proximate cause if the evidence and inferences that may reasonably be drawn from the evidence indicate that the negligence played a substantial part in bringing about or actually causing the injury or damage and that the injury or damage was either a direct result or a reasonably foreseeable consequence of the negligence.”
3 later decisions quote this exact passage“[p]roximate cause is generally a question of fact for the jury, but the court has a duty to direct a verdict for the defendant if the jury's deliberation [would] rest[ ] only on speculation or conjecture.”
2 later decisions quote this exact passage“[a]llowing a jury to infer causation on complex medical facts without the aid of expert testimony on the subject and without some showing that Wanger's conduct was 'more likely than not' a cause of Merriam's injury, stretches the jury's role beyond its capacity.”
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.