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← 219 Va. 969 - Farley v. Goode

Farley v. Goode’s Empirical Analysis

1979

Citation profile

133
cited by 133 later decisions
15
states following
September 2018
most recently cited

16 federal appellate · 2 district · 100 state decisions

How this case has been cited

Cited by 133 later decisions — most recently September 2018 · most notably 109 Wis. 2d 536 - Tamminen v. Aetna Casualty & Surety Co. (1982), Keller v. Denny (1987)

16 federal appellate · 2 district · 100 state decisions — followed in 15 states

51019791980199020002010decided

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 Borgia v. City of New York · Richmond Redevelopment & Housing Authority v. Laburnum Construction Corp. · Caudill v. Wise Rambler, Inc. · Comptroller Ex Rel. Virginia Military Institute v. King · Hawks v. DeHart

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

  1. “[W]hen malpractice is claimed to have occurred during a continuous and substantially uninterrupted course of examination and treatment in which a particular illness or condition should have been diagnosed in the exercise of reasonable care, the date of injury occurs, the cause of action for that malpractice accrues, and the statute of limitations commences to run when the improper course of examination, and treatment if any, for the particular malady terminates.”
    19 later decisions quote this exact passage · from the majority
  2. “by `continuous treatment' we do not mean mere continuity of a general physician-patient relationship; we mean diagnosis and treatment `for the same or related illnesses or injuries, continuing after the alleged acts of malpractice....'”
    5 later decisions quote this exact passage · from the majority
  3. “[A]s long as the physician-patient relationship continued as to a particular malady or injury, then it could not be said that treatment had ceased. Another part of our rationale in Farley was that unless a patient could properly wait to the end of treatment before being required to sue his or her physician, suits might have to be brought while the physician was in the midst of effecting a cure. We noted further that permitting a patient to wait until the termination of treatment before being required to file suit was conducive to mutual confidence between physician and patient because it gave the physician all reasonable time and opportunity to correct mistakes made at the beginning of a course of treatment. In Farley , we added an essential limitation on the rule of continuing treatment. We said it did not apply simply to a continuation of the physician-patient relationship. Ihstead, for the rule to apply, there had to exist continuing diagnosis and treatment for the same or related illnesses or injuries after the alleged acts of malpractice. We added further that the Farley rule applied only to “a continuous course of improper examination or treatment which is substantially uninterrupted” and not to single, isolated acts of negligence.”
    4 later decisions 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.