Young v. Flathead County’s Empirical Analysis
1988
Citation profile
39 state decisions
How this case has been cited
Cited by 39 later decisions — most recently March 2023 · most notably Busta Ex Rel. Busta v. Columbus Hospital Corp. (1996), Kitchen Krafters, Inc. v. Eastside Bank (1990)
39 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 Rudeck v. Wright · Dvorak v. Matador Service, Inc. · Sztaba v. Great Northern Railway Co. · Kyriss v. State · Demaree v. Safeway Stores, Inc.
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 39 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in a natural and continuous sequence, unbroken by any new, independent cause, produces injury, and without which the injury would not have occurred.”
3 later decisions quote this exact passage · from the majority“Liability, in any cause of action, attaches if the plaintiff can prove first that defendant's act is a cause in fact of injury and then that the injury is the direct or indirect result, proximately caused by the negligent act. Causation in fact has been determined by the use of the "but for" test . .. and in rare circumstances under a substantial factor examination. Prosser and Keeton, The Law of Torts, Section 41, pp. 264-268 (5th ed., 1984). In Montana, the distinction between causation in fact and proximate cause, now occasionally referred to as legal cause, has not generally been made... . Under causation in fact, the "but for" test has been defined as but for defendant's conduct, the event would not have occurred, or, conversely, defendant's conduct is not the cause of the event, if the event would have occurred without the conduct... . As an uncommon alternative to the "but for" test, the "substantial factor" test has been designed to deal with problems where application of the "but for" test would allow each of a number of defendants to escape responsibility because the conduct of one or more others would have been sufficient to produce the same result... .”
2 later decisions quote this exact passage · from the majority““Liability, in any cause of action, attaches if the plaintiff can prove first that defendant’s act is a cause in fact of injury and then that the injury is the direct or indirect result, proximately caused by the negligent act. Causation in fact has been determined by the use of the ‘but for’ test . . . “In Montana, proximate cause is one which in a natural and continuous sequence, unbroken by any new, independent cause, produces injury, and without which the injury would not have occurred. [Citations] This definition of proximate cause incorporates the ‘but for’ definition in the words of the last clause ‘[a]nd without which the injury would not have occurred.’ It is from this wording that the distinction between cause in fact and proximate, or legal, cause has become clouded.””
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.