Golt v. Phillips’s Empirical Analysis
1986
Citation profile
2 federal appellate · 26 district · 76 state decisions
How this case has been cited
Cited by 108 later decisions — most recently July 2022 · most notably Hartford Accident & Indemnity Co. v. Scarlett Harbor Associates Ltd. Partnership (1996), Green v. H & R BLOCK, INC. (1999)
2 federal appellate · 26 district · 76 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 Conaway v. Prestia · Charles of the Ritz Distributors Corp. v. Federal Trade Commission · Aronberg v. Federal Trade Commission · Harry Berenter, Inc. v. Berman · S.A.S. Personnel Consultants, Inc. v. Pat-Pan, Inc.
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 108 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Unfair or deceptive trade practices include any: (1) False, falsely disparaging, or misleading oral or written statement, visual description, or other representation of any kind which has the capacity, tendency, or effect of deceiving or misleading consumers; (2) Representation that: (i) Consumer ... realty ... have a sponsorship, approval, accessory, characteristic ... which they do not have.... (3) Failure to state a material fact if the failure deceives or tends to deceive...."”
7 later decisions quote this exact passage““Implicit in any advertisement and rental of an apartment is the representation that the leasing of the apartment is lawful. Baltimore City Code, Art. 13, § 1101 (1983 Repl. Vol.), expressly prohibits the operation of any multiple family dwelling without a license or temporary certificate. As Phillips Brothers had neither a license nor a temporary certificate, it violated the City Code. Phillips Brothers could not provide Golt with the unimpeded right to possession during the lease term. Consequently, Phillips Brothers advertisement and rental of the apartment was a ‘misleading ... statement ... or other representation of any kind which has the capacity, tendency, or effect of deceiving or misleading consumers.’ Maryland Code (1983 Repl.Vol.), § 13-301(1) of the Commercial Law Article. “Furthermore, such a representation is in essence a representation that the ‘realty ... [has] a sponsorship, approval ... [or] characteristic ... which [it does] not have,’ id. § 13-301(2)—namely, licensing for operation as a multiple family dwelling. It makes no difference that Appellees did not expressly state that the premises were properly licensed; such a basic prerequisite to any lease agreement is implied. For consumer protection purposes, the meaning of any statement or representation is determined not only by what is explicitly stated, but also by what is reasonably implied. Spiegel, Inc. v. Federal Trade Commission, 411 F.2d 481, 483 (7th Cir.1969); Aronberg v. Federal Trade Commissio”
4 later decisions quote this exact passage“"Section 13-408 of the CPA sets forth the private remedy created by the act: `any person may bring an action to recover for injury or loss sustained by him as the result of a practice prohibited by this title.' This private remedy is purely compensatory; it contains no punitive component. Indeed, any punitive assessment under the CPA is accomplished by an imposition of a civil penalty recoverable by the State under § 13-410, as well as by criminal penalties imposed under § 13-411. Thus, in determining the damages due the consumer, we must look only to his actual loss or injury caused by the unfair or deceptive trade practices. "”
4 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.