Hudson v. Jarrett’s Empirical Analysis
2005
Citation profile
26 state decisions
How this case has been cited
Cited by 29 later decisions — most recently February 2024 · most notably VIRGINIAN-PILOT MEDIA v. Dow Jones & Co. (2010), American Home Assurance Co. v. Eighth Judicial District Court of the State of Nevada ex rel. County of Clark (2006)
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
Applies 33 U.S.C. § 933
Relies on Bloomer v. Liberty Mutual Insurance · Mitchell v. The Etna · Smith v. Horn · Peters v. North River Insurance · Evans v. Hook
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.
“An employee subject to the provisions of the Workers’ Compensation Act cannot file an independent tort action against his employer or any fellow employee for injuries received in the course of employment. Code § 65.2-307; Pfeifer v. Krauss Const. Co., 262 Va. 262, 266 , 546 S.E.2d 717, 719 (2001). Under certain circumstances, Code § 65.2-302 extends this immunity from tort liability arising from workplace accidents to qualifying employers, even though no direct common law contract of employment exists between such employers and employees. An employer qualifies for this immunity if the employer, acting as a general contractor, contracts with another to perform all or part of the employer’s trade, business, or occupation. Under these circumstances, the employer is deemed the statutory employer of the employees of such other subcontractor and the remedies under the Act are the statutory employees’ exclusive remedy against the statutory employer. See id:, Evans v. Hook, 239 Va. 127, 131 , 387 S.E.2d 777, 779 (1990); Smith v. Horn, 232 Va. 302, 306 , 351 S.E.2d 14, 16 (1986). Similarly, employees of different subcontractors who are working on the same project and are also engaged in the general contractor’s trade, business, or occupation are considered statutory fellow employees and are entitled to protection from an independent tort action for injuries allegedly caused by either of them. Pfeifer, 262 Va. at 266-67 , 546 S.E.2d at 719 ; Evans, 239 Va. at 131 , 387 S.E.2d at 779 . ”
1 later decision quote this exact passage“[T]he Rule's history includes a strong adherence to limiting intervention to those parties who are legitimately plaintiffs or defendants ... because the nature of their claim includes some right that is involved in the litigation.”
1 later decision quote this exact passage“[t]he claims of the intervenors here fail to meet these conditions.”
1 later decision quote this exact passagee.g. Eads v. Clark
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.