Jackson v. Ivory’s Empirical Analysis
2003
Citation profile
2 federal appellate · 18 state decisions
How this case has been cited
Cited by 28 later decisions — most recently November 2025 · most notably Hardin v. Bishop (2013), Quinn III
2 federal appellate · 18 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 Flentje v. First Nat. Bank of Wynne · Clark v. Ridgeway · Madden v. Aldrich · McDonald v. Pettus · Nielsen v. Berger-Nielsen
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) No person licensed to practice law in Arkansas and no partnership or corporation of Arkansas licensed attorneys or any of its employees, partners, members, officers, or shareholders shall be liable to persons not in privity of contract with the person, partnership, or corporation for civil damages resulting from acts, omissions, decisions, or other conduct in connection with professional services performed by the person, partnership, or corporation, except for: (1) Acts, omissions, decisions, or conduct that constitutes fraud or intentional misrepresentations; or (2) Other acts, omissions, decisions, or conduct if the person, partnership, or corporation was aware that a primary intent of the client was for the professional services to benefit or influence the particular person bringing the action. For the purposes of this subdivision (a)(2), if the person, partnership, or corporation: (A) Identifies in writing to the client those persons who are intended to rely on the services, and (B) Sends a copy of the writing or similar statement to those persons identified in the writing or statement, then the person, partnership, or corporation or any of its employees, partners, members, officers, or shareholders may be held liable only to the persons intended to so rely, in addition to those persons in privity of contract with the person, partnership, or corporation.”
1 later decision quote this exact passage“We have stated that the plain language of section 16-22-310 requires the plaintiff to have direct privity of contract with the person, partnership, or corporation he or she is suing for legal malpractice. Nielsen v. Berger-Nielsen, 347 Ark. 996 , 69 S.W.3d 414 (2002); Madden v. Aldrich, 346 Ark. 405 , 58 S.W.3d 342 (2001); McDonald v. Pettus, 337 Ark. 265 , 988 S.W.2d 9 (1999). Privity of contract is defined as “that connection or relationship which exists between two or more contracting parties.” Swink v. Ernst & Young, 322 Ark. 417, 420-21 , 908 S.W.2d 660 (1995) (citing. Black’s Law Dictionary 1079 (5th ed.1979)). We have narrowly construed the privity requirement to require direct privity between the plaintiff and the attorney or entity to be held liable for legal malpractice. McDonald, supra; Clark v. Ridgeway, 323 Ark. 378 , 914 S.W.2d 745 (1996). In Clark, we stated that “the language of this section [16-22-310(a) ] is precise and clear and reveals that the contract contemplated by the statute relates to a contract for professional ser-vicés performed by the attorney for the client.” 323 Ark. at 386 , 914 S.W.2d 745 .”
1 later decision 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.