Ryan v. Connor’s Empirical Analysis

Citation profile

76 state decisions

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 76 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““ ‘Injury’ includes any injury, whether caused by external accidental means or accidental in character and result, received in the course of, and arising out of, the injured employee’s employment. ‘Injury’ does not include: “(1) Psychiatric conditions except where the conditions have arisen from an injury or occupational disease; “(2) Injury or disability caused primarily by the natural deterioration of tissue, an organ, or part of the body; “(3) Injury or disability incurred in voluntary participation in an employer-sponsored recreation or fitness activity if the employee signs a waiver of his right to compensation or benefits under Chapter. 4123. of the Revised Code prior to engaging in the recreation or fitness activity.””

   3 later decisions quote this exact passage · from the dissent
   e.g. 98 Ohio App. 3d 754 - Waddington v. Levison · 85 Ohio App. 3d 583 - Small v. Defiance Public Library

2. “{¶ 7} “[1.] The trial court erred in excluding from testimony the opinion of plaintiffs expert witness, Dr. Charles V. Mattingly, that the stress experienced by the plaintiff causing her myocardial infarction was greater emotional strain or tension that that to which all workers are occasionally subjected. {¶ 8} “[2.] The trial court erred in excluding from evidence a medical review report by Dr. Nancy Vaughan commissioned by the Bureau of Workers’ Compensation together with cross-examination testimony upon that review. {¶ 9} “[3.] The trial court erred in excluding from evidence cross-examination testimony of defendant’s expert medical witness relating to opinions contained in three medical reports submitted to him for review by the defendant. {¶ 10} “[4.] The trial court erred in excluding from evidence plaintiffs testimony that she had read and corrected her deposition. {¶ 11} “[5.] The trial court erred in excluding from evidence a job description document filed by a representative of the employer at a hearing before the Industrial Commission.””

   2 later decisions quote this exact passage · from the dissent
   e.g. Henry v. Lincoln Elec. Holdings, 90182 (7-10-2008) · 146 Ohio App. 3d 772 - Bishop v. Ohio Bureau of Workers' Compensation

3. “Under the “sudden mishap” test as previously recognized by this court, the determinative factor was the ability of the employee to isolate a specific event upon which to rest his claim. The practical result of this distinction was to preclude recovery in those instances where the employee could not point to an isolated, traumatic external event as the cause of his disability. In the area of injuries occasioned over a period of time while acting in the course of his employment, the burden was insurmountable in most cases for the employee as there was not a sudden occurrence but, rather, a continual degenerative condition. ❖ * * A heart attack brought on by a sudden and dramatic stimulus, such as a severe muscular strain, is clearly compensable under our statute. However, closer questions are involved when the employment contribution is a more protracted burden such as worry, frustration, overwork, anxiety, and other stressful conditions. In this situation, medical testimony can never be certain that the heart failure or cerebral hemorrhage was entirely due to the employee’s working environment. Thus, the factual issue of causal relationship is generally for the medical experts and the triers of fact.”

   1 later decision quote this exact passage · from the dissent
   e.g. Mataraza v. City of Euclid