Simon v. Zipperstein’s Empirical Analysis
1987
Citation profile
1 federal appellate · 2 district · 111 state decisions
How this case has been cited
Cited by 131 later decisions — most recently March 2026 · most notably Floor Craft Floor Covering, Inc. v. Parma Community General Hospital Ass'n (1990), LeRoy v. Allen, Yurasek & Merklin (2007)
1 federal appellate · 2 district · 111 state decisions — followed in 10 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 Temple v. Wean United, Inc. · 56 Cal. 2d 583 - Lucas v. Hamm · Savings Bank v. Ward · Whitehead v. General Telephone Co. · Guy v. Liederbach
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 131 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[s]ome immunity from being sued by third persons must be afforded an attorney so that he may properly represent his client.'”
9 later decisions quote this exact passage · from the majority“It is by now well-established in Ohio that an attorney may not be held liable by third parties as a result of having performed services on behalf of a client, in good faith, unless the third party is in privity with the client for whom the legal services were performed, or unless the attorney acts with malice.”
8 later decisions quote this exact passage · from the majority“[t]he necessity for privity may be overridden if special circumstances such as 'fraud, bad faith, collusion or other malicious conduct' are present.”
5 later decisions quote this exact passage · from the majority
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.