414 Pa. Super. 231 - Love v. Cramer’s Empirical Analysis
1992
Citation profile
67 state decisions
How this case has been cited
Cited by 85 later decisions — most recently November 2022 · most notably 430 Pa. Super. 36 - Armstrong v. Paoli Memorial Hospital (1993), 424 Pa. Super. 121 - KRYSMALSKI BY KRYSMALSKI v. Tarasovich (1993)
67 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 Sinn v. Burd · Mazzagatti v. Everingham by Everingham · 293 Pa. Super. 122 - Banyas v. Lower Bucks Hospital · Kyle v. McNamara & Criste · 409 Pa. Super. 83 - Bloom v. DuBois Regional Medical Center
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 85 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) plaintiff was located near the scene of the accident as contrasted with one who was a distance away from it; (2) the shock resulted from a direct emotional impact on plaintiff from the sensory and contemporaneous observance of the accident, as contrasted with learning of the accident from others after its occurrence; and (3) plaintiff and the victim were closely related as contrasted with an absence of any relationship or the presence of only a distant relationship.”
3 later decisions quote this exact passage““Although appellant may be unable to ultimately prove a causal connection between her injuries and the doctor’s alleged negligence, she should at least be given the opportunity to do so. This is not the simple situation wherein the plaintiff did not observe the traumatic event, but nevertheless sought to recover for emotional distress. Rather appellant witnessed the traumatic event, and the earlier negligence of the doctor. Her recovery, if proven, would be based upon the fact that her emotional injury was due to her first hand observation of her mother’s heart attack, an event caused by Dr. Cramer’s negligence, which she had also witnessed. As such, it cannot be said with certainty that appellant will be unable to recover under the law. She should be given the opportunity to prove that Dr. Cramer was negligent, and that his negligence was a proximate cause of her emotional distress. Therefore, the preliminary objections should not have been granted.””
2 later decisions quote this exact passage“The basis of recovery for a claim of negligent infliction of emotional distress is the traumatic impact of viewing the negligent injury of a close relative. A person who does not experience a sensory and contemporaneous observance of the injury does not state a cause of action for negligent infliction of emotional distress. In formulating the rule, the Supreme Court “contemplated a discrete , and identifiable traumatic event to trigger recovery.” In the absence of such an event, no recovery is permitted.”
2 later decisions 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.