Werner v. Lane’s Empirical Analysis
1978
Citation profile
2 federal appellate · 4 district · 26 state decisions
How this case has been cited
Cited by 32 later decisions — most recently August 2024 · most notably Washington Ex Rel. Washington v. Barnes Hospital (1995), Weborg v. Jenny (2012)
2 federal appellate · 4 district · 26 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 2 Cal. 3d 1 - Helfend v. Southern California Rapid Transit District · Tipton v. Socony Mobil Oil Co. · Pryor v. Webber · Long v. Landy · Gorham v. Farmington Motor Inn, Inc.
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The overwhelming weight of authority in the country is to the effect that the fact necessary medical and nursing services are rendered gratuitously to one who is injured as a result of the negligence of another should not preclude the injured party from recovering the reasonable value of those services as part of his compensatory damages in an action against the tortfeasor. This is known as the collateral source rule. Stated otherwise, it means that, if a plaintiff is compensated in whole or in part for his damages by some source independent of the tortfeasor, he is still permitted to have full recovery against him.”
2 later decisions quote this exact passage“Defense counsel's statement to the jury respecting the free medical and hospitalization care furnished [the plaintiff] ... was so highly prejudicial to the plaintiffs case.. . that it cannot be said with any degree of certainty that the jury did not conclude that, since the plaintiff was otherwise being taken care of, there should be no recovery at all against [the defendant], notwithstanding the uncontradicted aspect of the evidence pointing to negligence on the part of the defendant proximately causing the accident. 9”
1 later decision quote this exact passagee.g. Weborg v. Jenny“In deciding the correctness of the action taken by the presiding Justice we cannot substitute our judgment for his. His order may be reversed by us only ‘in the event that a clear and manifest abuse of discretion on the part of the trial judge is shown.’”
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.