Taylor v. Phillips’s Empirical Analysis
1990
Citation profile
18 state decisions
How this case has been cited
Cited by 22 later decisions — most recently December 2024
18 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 Waldman v. Rohrbaugh · Farley v. Goode · Lane v. Lane · 75 Wash. 2d 894 - Samuelson v. Freeman · Metzger v. Kalke
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]f the treatment by the doctor is a continuing course and the patient’s illness, injury or condition is of such a nature as to impose on the doctor a duty of continuing treatment and care, the statute does not commence running until treatment by the doctor for the particular disease or condition involved has terminated — unless during treatment the patient learns or should learn of negligence, in which case the statute runs from the time of discovery, actual or constructive.”
3 later decisions quote this exact passagee.g. Preer v. Mims · Raynor v. Kyser“In this case, Taylor was clearly under a continuing course of treatment by Phillips, and so the statute did not begin to ran until Taylor’s treatment terminated on December 9, 1987. Taylor still had the brace screwed into his jaw bones on December 9 when Phillips and his partner agreed that Taylor needed further surgery on his jaw. Taylor’s complaint against Phillips was filed on October 16, 1989, well within the statute of limitations. To hold otherwise might require a plaintiff to bring suit against his or her physician before treatment is even terminated. This could conceivably afford the physician a defense that a patient left before treatment was terminated and before the physician had a chance to effectuate a proper result.”
2 later decisions quote this exact passage“(a) Except as otherwise provided in this section, all actions for medical injury shall be commenced within two (2) years after the cause of action accrues. (b) The date of the accrual of the cause of action shall be the date of the wrongful act complained of and no other time. . . .”
2 later decisions quote this exact passage · from the concurrence
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.