Smalls v. Wright’s Empirical Analysis
1991
Citation profile
3 federal appellate · 26 state decisions
How this case has been cited
Cited by 37 later decisions — most recently January 2018 · most notably Williams v. Garraghty (1995), Government Micro Resources, Inc. v. Jackson (2006)
3 federal appellate · 26 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 Public Service Commission v. Chesapeake & Potomac Telephone Co. · Allied Corp. v. District 17, United Mine Workers · Gazette, Inc. v. Harris · Great Coastal Express, Inc. v. Ellington · Compton v. New Mexico
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a] communication, made in good faith on a subject in which the communicating party has an interest or owes a duty, is qualifiedly privileged if the communication is made to a party who has a corresponding interest or duty.”
3 later decisions quote this exact passage · from the majority“(1) the defendant knew the statement was false or made it with reckless disregard of whether it was false or not; or (2) the statement was deliberately made in such a way that it was heard by persons having no interest or duty in the subject matter of the statement; or (3) the statement was unnecessarily insulting; or (4) the language used was stronger or more violent than necessary under the circumstances; or (5) the statement was made because of hatred, ill will, or a desire to hurt the plaintiff rather than as a fair comment on the subject.”
2 later decisions quote this exact passage · from the majority“[I]n order to avoid the privilege it is necessary for the plaintiff to show that the words were spoken with malice in fact, actual malice, existing at the time the words were spoken; that is, that the communication was actuated by some sinister or corrupt motive such as hatred, revenge, personal spite, ill will, or desire to injure the plaintiff; or what, as a matter of law, is equivalent to malice, that the communication was made with such gross indifference and recklessness as to amount to a wanton or wilful disregard of the rights of the plaintiff.”
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.