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← 401 S.W.2d 43 - Ratliff v. Epling

Ratliff v. Epling’s Empirical Analysis

1966

Citation profile

20
cited by 20 later decisions
3
states following
December 2014
most recently cited

20 state decisions

How this case has been cited

Cited by 20 later decisions — most recently December 2014

20 state decisions

60196619701980199020002010decided

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 Phil Hollenbach Co. v. Hollenbach · Big Elkhorn Coal Co. v. Burke · A. C. Lawrence Leather Co. v. Barnhill · Bennett v. Vanderbilt University · 158 Pa. Super. 448 - Young v. Hamilton Watch Co.

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

  1. ““... It may be generally stated that (in the absence of the performance of some employment duties) the employee is not covered if he is not on the premises of the employer. . .. On the other hand, we have not adopted the converse rule (which generally prevails) that the employee is automatically covered simply because the accident occurred on the employer’s premises...”
    2 later decisions quote this exact passage
  2. ““The Pennsylvania courts have taken what appears to be a fairer and more practical view of what constitutes ‘premises.’ In Young v. Hamilton Watch Co., 158 Pa.Super. 448 , 45 A.2d 261 , a distinction was made between the ‘premises’ and the ‘property’ of the employer. It was held that where the injury did not occur on the ‘operating premises’ of the employer, compensation would be denied. The same general principle was followed in Connecticut (Flodin v. Henry & Wright Mfg. Co., 131 Conn. 244 , 38 A.2d 801 ) and Tennessee (Bennett v. Vanderbilt University, 198 Tenn. 1 , 277 S.W.2d 386 ). “The ‘operating premises’ concept is somewhat related to the idea expressed by this Court in Barker v. Eblen Coal Company, Ky., 276 S.W.2d 448 , where the test applied was: ‘work connected activity*. If we interpret ‘work connected activity’ as including ‘work connected place’, we really reach the concept of ‘operating premises’. See Kentucky Law Journal, Cooper, ‘Workmen’s Compensation — The “Going and Coming” Rule and Its Exceptions in Kentucky’, 47 Ky. L.J., pages 420, 424. (This might be considered a justifiable extension of the ‘industrial hazard’ theory.) “The ‘operating premises’ principle appears implicit in the following cases: Phil Hollenbach Co. v. Hollenbach, 181 Ky. 262 , 204 S.W.152, [ 13 A.L.R. 524 ]; Barres v. Watterson Hotel Co., 196 Ky. 100, 244 S.W. 308 ; Big Elkhorn Coal Co. v. Burke, 206 Ky. 489 , 267 S.W. 142 ; Wilson Berger Coal Co. v. Brown, 223 Ky. 183 , 3 S.W.2d 199 ; ”
    1 later decision quote this exact passage
  3. ““In our opinion the ‘operating premises’ test is a fair one and most consistent with the trend of our decisions, and we hereby adopt it. Applying it to this case, we find that the roadway area extending at least as far as the point opposite which the employee was killed (173 feet from the drift mouth) properly should have been considered within the ‘operating premises’ of the employer by the Board.” Id., 401 S. W.2d 45 .”
    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.