202 N.J. Super. 255 - State v. Pavin’s Empirical Analysis
1985
Citation profile
30 state decisions
How this case has been cited
Cited by 30 later decisions — most recently March 2002 · most notably 223 N.J. Super. 409 - State v. Bogus (1988), State v. Gardner (1989)
30 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 State v. Roth · State v. Kociolek · State v. Hodge · In Re Kozlov · 30 Ill. 2d 456 - The People v. Ryan
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 30 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[N]o blanket privilege with respect to communications between an insured and his adjuster should be countenanced. Rather the privilege should be held to shield communications between the insured and the adjuster only where the communications were in fact made to the adjuster for the dominant purpose of the defense of the insured by the attorney and where confidentiality was the reasonable expectation of the insured. [ Id. at 262 , 494 A. 2d 834 .]”
3 later decisions quote this exact passage · from the majority“The statement is ordinarily used by the insurer to determine whether and on what basis adjustment of the claim could be attempted. Only if adjustment is not effected and a claim is pursued, will the information be turned over to counsel for use in litigation. If the insured gives a false statement, or a statement which supplies facts regarding some other defense against the insurer's liability under the policy, the insurer can make use of those facts to the detriment of the insured. Thus, these cases say that the relationship is not automatically comparable at all stages to that of attorney and client, since it is not at all clear that insured's interests are being protected by the insurance carrier. [ Id. at 261-62 , 494 A. 2d 834 .]”
1 later decision quote this exact passage · from the majority“There was no evidence ... that the insurance adjuster was acting in accordance with instructions from his employer's attorney, or that an attorney had even been retained by the carrier to review the file. At this early stage, the adjuster was representing the interests of his principal, the insurance company, and not those of the insured. [ Id. at 263 , 494 A. 2d 834 .]”
1 later decision 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.