Waddle v. Sparks’s Empirical Analysis
1992
Citation profile
13 federal appellate · 2 district · 93 state decisions
How this case has been cited
Cited by 190 later decisions — most recently August 2025 · most notably Rhyne v. K-Mart Corp. (2004), Hartsell v. Duplex Products, Inc. (1997)
13 federal appellate · 2 district · 93 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 Stanback v. Stanback · Dickens v. Puryear · Pembee Mfg. Corp. v. Cape Fear Const. Co., Inc. · 79 N.C. App. 483 - Hogan v. Forsyth Country Club Co. · Johnson v. Ruark Obstetrics & Gynecology Associates, P.A.
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 190 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“any emotional or mental disorder, such as, for example, neurosis, psychosis, chronic depression, phobia, or any other type of severe and disabling emotional or mental condition which may be generally recognized and diagnosed by professionals trained to do so.”
12 later decisions quote this exact passage · from the dissent“[A claim for emotional distress] applies only where the emotional distress has in fact resulted, and where it is severe. Emotional distress passes under various names, such as mental suffering, mental anguish, mental or nervous shock, or the like.... It is only where it is extreme that the liability arises.... The law intervenes only where the distress inflicted is so severe that no reasonable man could be expected to endure it. The intensity and the duration of the distress are factors to be considered in determining its severity. ... It is for the court to determine whether on the evidence severe emotional distress can be found[.]”
7 later decisions quote this exact passage · from the dissent“The essential elements of an action for intentional infliction of emotional distress are `1) extreme and outrageous conduct by the defendant 2) which is intended to and does in fact cause 3) severe emotional distress.'”
3 later decisions quote this exact passage · from the dissent
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.