Palmer v. State’s Empirical Analysis
1960
Citation profile
74 state decisions
How this case has been cited
Cited by 79 later decisions — most recently March 2026 · most notably State v. Fabritz (1975), Degren v. State (1999)
74 state decisions — followed in 12 states
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 Ex Rel. Schiller v. Hecht Co. · Holler v. Lowery · Craig v. State · Conowingo Power Co. v. Maryland · Jubb v. Ford
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.
“It is not essential to the existence of a causal relationship that the ultimate harm which has resulted was foreseen or intended by the actor. It is sufficient that the ultimate harm is one which a reasonable man would foresee as being reasonably related to the acts of the defendant.”
9 later decisions quote this exact passage · from the majoritye.g. State v. Zobel · State v. Thomas“[T]o establish civil liability, the rule, generally, is a failure to use that degree of care and caution that an ordinarily careful and prudent person would exercise under like circumstances. But, in Maryland, if the basis of the charge be felonious negligence as it is in the instant case, it must have been gross or criminal negligence, which has been interpreted by this Court to mean “a wanton or reckless disregard for human life.””
3 later decisions quote this exact passage · from the majority“deplorable and distressing set of circumstances”
1 later decision quote this exact passage · from the majoritye.g. State v. Zobel
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.