Adams v. Coates’s Empirical Analysis
1993
Citation profile
10 district · 44 state decisions
How this case has been cited
Cited by 55 later decisions — most recently June 2016 · most notably Philip Morris Inc. v. Angeletti (2000), Montgomery Ward v. Wilson (1995)
10 district · 44 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 Owens-Illinois, Inc. v. Zenobia · Martens Chevrolet, Inc. v. Seney · H & R BLOCK, INC. v. Testerman · Wedeman v. City Chevrolet Co. · Superior Construction Co. v. Elmo
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 55 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he trier of fact has discretion to deny punitive damages even where the record otherwise would support their award.”
3 later decisions quote this exact passage““As an alternative analysis, Adams contends that both Counts II and V, and particularly Count V, can be viewed as alleging a tort, which Adams labels as the tort of ‘breach of fiduciary duty.’ Restatement (Second) of Torts § 874, captioned ‘Violation of Fiduciary Duty,’ states the rule that ‘[o]ne standing in fiduciary relation with another is subject to liability to the other for harm resulting from a breach of duty imposed by the relation.’ Breach of fiduciary duty, as a tort, has been alleged by pleaders whose cases have come to this Court, and our opinions have used the term to describe claims asserted, but we have not opined on the existence of the tort or torts, or on its or their elements or rules of damages____ We need not so opine in this case. “The only issue for decision in the matter before us that turns on whether breach of fiduciary duty between partners can be asserted as a tort involves whether punitive damages are recoverable by Adams under the proof in this case. Whether punitive damages are recoverable is not determined exclusively by the elements of the tort, but depends primarily on Maryland policy as to the award of punitive damages. We shall assume, solely for the purpose of discussion in this case, the existence of a tort, and that, under proper proof, the tort can be the springboard for punitive damages.””
2 later decisions quote this exact passage““ ‘[P]unitive damages are awarded in an attempt to punish a defendant whose conduct is characterized by evil motive, intent to injure, or fraud, and to warn others contemplating similar conduct of the serious risk of monetary liability.’ ””
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.