Surace v. Wuliger’s Empirical Analysis
1986
Citation profile
2 federal appellate · 100 state decisions
How this case has been cited
Cited by 123 later decisions — most recently January 2026 · most notably Hecht v. Levin (1993), M.J. DiCorpo, Inc. v. Sweeney (1994)
2 federal appellate · 100 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 138 Ohio St. 574 - Bigelow v. Brumley · 122 Ohio St. 210 - Erie County Farmers' Ins. v. Crecelius · Arthur Theiss v. Gordon H. Scherer · Vieira v. Meredith · 69 Ohio App. 2d 75 - Justice v. Mowery
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 123 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““As a matter of public policy, under the doctrine of absolute privilege in a judicial proceeding, a claim alleging that a defamatory statement was made in a written pleading does not state a cause of action where the allegedly defamatory statement bears some reasonable relation to the judicial proceeding in which it appears.””
7 later decisions quote this exact passage“The late Dean Prosser once noted that '[t]he defense of privilege, or immunity, in cases of defamation does not differ essentially from the privileges, such as those of self-defense, protection of property, or legal authority, available as to assault and battery. It rests upon the same idea, that conduct which otherwise would be actionable is to escape liability because the defendant is acting in furtherance of some interest of social importance, which is entitled to protection even at the expense of uncompensated harm to the plaintiff's reputation.’”
3 later decisions quote this exact passage“'No action will lie of any defamatory statement made by a party to a court proceeding, in a pleading filed in such proceeding, where the defamatory statement is material and relevant to the issue.'”
3 later decisions 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.