23 Wash. App. 277 - Pena v. Thorington’s Empirical Analysis
1979
Citation profile
3 federal appellate · 20 state decisions
How this case has been cited
Cited by 29 later decisions — most recently December 2002 · most notably Mahler v. Szucs (1998), Mahler v. Szucs (1998)
3 federal appellate · 20 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 54 Wash. 2d 570 - Thorndike v. Hesperian Orchards, Inc. · United Services Automobile Association v. Hills · Krause v. State Farm Mutual Automobile Insurance · 48 Wis. 2d 290 - State Farm Mutual Automobile Insurance v. Geline · National Union Fire Insurance Company v. Grimes
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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A]n insurer who makes a recovery from a third party for moneys paid its insured is only required to pay attorney fees which were "reasonably and necessarily incurred" to make the recovery. Absent an agreement to the contrary, an insurer is only obligated for attorney fees if it is benefited.”
2 later decisions quote this exact passage“State Farm [the insurer] corresponded directly with adjusters for Colonial Penn [the tortfeasor's insurer], or with Colonial Penn's own attorney, in efforts to negotiate payment of State Farm's subrogation interest. Given [the fact the tortfeasor's liability was clear] State Farm had a reasonable basis for believing that it would be successful in recovering its claim, and that Colonial Penn would pay State Farm's interest without the necessity of State Farm participating in this litigation.”
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.