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← 37 OHIOST3D 118 - Waller v. Mayfield

Waller v. Mayfield’s Empirical Analysis

1988

Citation profile

50
cited by 50 later decisions
5
states following
September 2024
most recently cited

1 federal appellate · 49 state decisions

How this case has been cited

Cited by 50 later decisions — most recently September 2024 · most notably 89 Ohio App. 3d 35 - Stewart v. B.F. Goodrich Co. (1993), 47 Ohio App. 3d 1 - Delker v. Ohio Edison Co. (1989)

1 federal appellate · 49 state decisions

14019881990200020102020decided

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 Van Fossen v. Babcock & Wilcox Co. · 145 Ohio St. 198 - Stevens v. Industrial Commission · O'Day v. Webb · Lord v. Daugherty · Bralley v. Daugherty

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 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “an employee's preexisting physical weakness or disease which contributes to the accident.”
    3 later decisions quote this exact passage · from the concurrence
  2. ““An injury sustained by an employee that is compensable under the Workers’ Compensation Act ‘includes any injury, whether caused by external accidental means or accidental in character and result, received in the course of, and arising out of the injured employee’s employment.’ R.C. 4123.01(C). It is undisputed that appellee sustained his injury while in the course of his employment. (( * * * “[However,] there must be some causal connection between the employment and the injury. * * * “An injury caused by an unexplained slip or fall presents a unique case under the workers’ compensation laws. As Professor Larson notes: ‘All risks causing injury to a claimant can be brought within three categories: risks distinctly associated with the employment, risks personal to the claimant, and “neutral” risks — i.e., risks having no particular employment or personal character. Harms from the first are universally compensable. Those from the second are universally noncompensable. It is within the third category that most controversy in modern compensation law occurs. * * *’ 1 Larson, The Law of Workmen’s Compensation (1985) 3-12, Section 7.00. * * * « * * * “ ‘It should be stressed * * * [internal weakness causing a fall], although often discussed in the same breath with unexplained falls, is basically different, since unexplained fall cases begin with a completely neutral origin of the mishap, while idiopathic fall cases begin with an origin which is admittedly personal and which therefor”
    2 later decisions quote this exact passage
  3. “an inference arises that the [injury] is traceable to some ordinary risk, albeit unidentified, to which the employee was exposed on the employment premises.”
    2 later decisions quote this exact passage · from the concurrence

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.