Bates v. Campbell’s Empirical Analysis
1931
Citation profile
19 federal appellate · 2 district · 56 state decisions
How this case has been cited
Cited by 79 later decisions — most recently November 2010 · most notably 1 Cal. 3d 20 - Kapellas v. Kofman (1969), 52 Cal. 2d 536 - MacLeod v. Tribune Publishing Co. (1959)
19 federal appellate · 2 district · 56 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 Stevens v. Snow · Schomberg v. Walker · Hearne v. De Young · Tonini v. Cevasco · Chavez v. Times-Mirror Co.
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 79 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'Libel is a false and unprivileged publication by writing ... which exposes any person to hatred, contempt, ridicule, or obloquy, or which causes him to be shunned or avoided, or which has a tendency to injure him in his occupation.' (Civ. Code, sec. 45.) ... These definitions have been held to include almost any language which, upon its face, has a natural tendency to injure a person's reputation, either generally, or with respect to his occupation. (Bates v. Campbell, 213 Cal. 438, 441 [ 2 P.2d 383 ]; Stevens v. Snow, 191 Cal. 58, 62 [ 214 P. 968 ]; Schomberg v. Walker, 132 Cal. 224, 227 [ 64 P. 290 ]; Tonini v. Cevasco, 114 Cal. 266, 272 [ 46 P. 103 ]); and words clearly conveying a meaning within one of the statutory categories are actionable per se.”
2 later decisions quote this exact passage“the publication is to be measured, not so much by its effect when subjected to the critical analysis of a mind trained in the law, but by the natural and probable effect upon the mind of the average reader.”
2 later decisions quote this exact passage“it is not the purpose of an innuendo to `beget an action', and the meaning of the language complained of may not be enlarged or extended thereby. [Citations.] In other words, it is the office of the innuendo to merely explain or interpret, without enlarging, the alleged libelous publication.”
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.