Ennis v. Crenca’s Empirical Analysis
1991
Citation profile
4 federal appellate · 6 district · 48 state decisions
How this case has been cited
Cited by 58 later decisions — most recently August 2020 · most notably Barbre v. Pope (2007), 140 Md. App. 282 - Baltimore Police Department v. Cherkes (2001)
4 federal appellate · 6 district · 48 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 Hutchinson v. Proxmire · 30 Cal. 3d 770 - Kilgore v. Younger · Motors, Inc. v. Times Mirror Co. · Attorney Grievance Commission v. Alperstein · Sawyer v. Humphries
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 58 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he general test ... for determining if an employee’s tortious acts were within the scope of his employment is whether they were in furtherance of the employer’s business and were “authorized” by the employer.... “ ‘By authorized is not meant authority expressly conferred, but whether the act was such as was incident to the performance of the duties entrusted to him by the master, even though in opposition to his express and positive orders.’ ” ... “To be within the scope of the employment, conduct must be of the same general nature as that authorized, or incidental to the conduct authorized.” ... [A]n important factor is whether the employee’s conduct was “expectable” or “foreseeable.” ... [Particularly in cases involving intentional torts committed by an employee, this Court has emphasized that where an employee’s actions are personal, or where they represent a departure from the purpose of furthering the employer’s business, or where the employee is acting to protect his own interests, even if during normal duty hours ..., the employee’s actions are outside the scope of his employment.... “Where the conduct of the servant is unprovoked, highly unusual, and quite outrageous,” courts tend to hold “that this in itself is sufficient to indicate that the motive was a purely personal one” and the conduct outside the scope of employment.”
5 later decisions quote this exact passage““Furthermore, and particularly in cases involving intentional torts committed by an employee, this Court has emphasized that where an employee’s actions are personal, or where they represent a departure from the purpose of furthering the employer’s business, or where the employee is acting to protect his own interests, even if during normal duty hours and at an authorized locality, the employee’s actions are outside the scope of his employment.””
3 later decisions quote this exact passage“(b) When government liable.—(1) Except as provided in subsection (c) of this section, a local government shall be liable for any judgment against its employee for damages resulting from tortious acts or omissions committed by the employee within the scope of employment with the local government.... (c) Punitive damages; indemnification.—(1) A local government may not be liable for punitive damages.”
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.