The Buckeye State’s Empirical Analysis
1941
Citation profile
2 federal appellate · 1 district · 4 state decisions
How this case has been cited
Cited by 10 later decisions (2 by the Supreme Court) — most recently June 1983
2 federal appellate · 1 district · 4 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 Schnell v. The Vallescura · Workman v. Boone · Earle & Stoddart, Inc. v. Ellerman's Wilson Line, Ltd. · Atlantic Coast Line Railroad v. Powe · Mitchell v. Potomac Insurance
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 10 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Fire is always caused by combustion, but combustion does not always cause fire. The word ‘spontaneous’ refers to the origin of the combustion. It means the internal development of heat without the action of an external agent. Combustion, or spontaneous combustion, may become so rapid as to produce fire; but, until it does so, combustion cannot be said to be fire. ‘Fire’ is defined in the Century Dictionary as ‘the visible heat or light evolved by the action of a high temperature on certain bodies, which are in consequence styled “inflammable or combustible.” ’ In Webster’s Dictionary ‘fire’ is defined as ‘the evolution of light and heat in the combustion of bodies.’ No definition of fire can be found that does not include the idea of visible heat or light, and this is also the popular meaning given to the word.”
1 later decision quote this exact passage · from the majority
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.