Joseph E. Thomas v. Ruth A. Martin Hogan’s Empirical Analysis
308 F.2d 355 · 1962
Citation profile
45 federal appellate · 2 district · 33 state decisions
How this case has been cited
Cited by 90 later decisions — most recently March 2022 · most notably Gass v. United States (1969), United States v. Bohle (1971)
45 federal appellate · 2 district · 33 state decisions — followed in 18 states
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 Erie Co v. Tompkins · Palmer v. Hoffman · Byrd v. Blue Ridge Rural Electric Cooperative, Inc. · Crane v. Tunks · Lyles v. United States
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 90 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Human life will often depend on the accuracy of the entry, and it is reasonable to presume that a hospital is staffed with personnel who competently perform their day-to-day tasks. To this extent at least, hospital records are deserving of a presumption of accuracy even more than other types of business entries. (Footnote omitted.) [Thomas v. Hogan, 308 F.2d 355, 361 (4th Cir. 1962).]”
3 later decisions quote this exact passage““We do not agree that the entry, to be admissible, must speak, not only of the diagnosis or the result of the test, but must also state affirmatively the qualifications of the diagnostician or of the technician and the steps taken in running the test. We read the statute as supplying a presumption that diagnoses and scientific tests are properly made by qualified personnel, if the recorded information reflects usual routine of the hospital and if it is the practice to record such data contemporaneously or within a reasonable time.””
2 later decisions quote this exact passage“[e]xceptions to the hearsay rule * * * are deemed justified * * * [when] the circumstances assure the probable verity of the evidence.”
2 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.