Gupton v. Quicke’s Empirical Analysis
1994
Citation profile
19 state decisions
How this case has been cited
Cited by 25 later decisions — most recently July 2012 · most notably Yuzefovsky v. St. John's Wood Apartments (2001), Thompson Ex Rel. Thompson v. Skate America, Inc. (2001)
19 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 Gulf Reston, Inc. v. Rogers · Wright v. Webb · Klingbeil Management Group Co. v. Vito
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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Virginia adheres to the rule “that the owner or occupier of land ordinarily is under no duty to protect an invitee from a third person’s criminal act committed while the invitee is upon the premises.” Gupton v. Quicke, 247 Va. 362, 363 , 442 S.E.2d 658, 658 (1994) (citing Wright v. Webb, 234 Va. 527, 530 , 362 S.E.2d 919, 920 (1987)). In Wright , we fashioned a narrow, limited exception to the general rule. There, we held that an owner or occupier of land, “whose method of business does not attract or provide a climate for assaultive crimes, does not have a duty to take measures to protect an invitee against criminal assault unless he knows that criminal assaults against persons are occurring, or are about to occur, on the premises which indicate an imminent probability of harm to an invitee.” 234 Va. at 533 , 362 S.E.2d at 922 . This exception requires “notice of a specific danger just prior to the assault.””
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.