Walters v. Ditzler’s Empirical Analysis
1967
Citation profile
12 federal appellate · 126 state decisions
How this case has been cited
Cited by 174 later decisions — most recently October 2014 · most notably Pocono International Raceway, Inc. v. Pocono Produce, Inc. (1983), Elizabeth Arnold Lake v. Frederick S. Arnold (2000)
12 federal appellate · 126 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 Schaffer v. Larzelere · Nesbitt v. Erie Coach Co. · Walker v. Mummert · Schwab v. Cornell · Bonfitto v. Bonfitto
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 174 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) Mere mistake, misunderstanding or lack of knowledge do not toll the running of the statute of limitations: Schaffer v. Larzerlere, 410 Pa. 402, 405 , 189 A.2d 267 (1963) and authorities therein cited; (b) If, through fraud, deception or concealment of facts, an insurance company lolls an injured person or his representatives into a sense of security so that such person’s vigilance is relaxed, then the company is estopped from asserting the statute: Schaffer v. Larzelere, supra, p. 405, 189 A.2d 267 , and authorities therein cited; (c) The fraud which will toll the statute and effect an estoppel need not be fraud in the strictest sense, i. e. inclusive of an intent to deceive, but may be fraud in the broad sense, i. e. inclusive of an unintentional deception: Nesbitt v. Erie Coach Co., 416 Pa. 89, 96 , 204 A.2d 473 (1964); Schweb v. Cornell, 306 Pa. 536, 539 , 160 A. 449 (1932); (d) An estoppel becomes operative only in clear cases of fraud, deception or concealment . . . pp. 449-450, 227 A.2d p. 835.”
6 later decisions quote this exact passage“[a] review of [the] record convinces . . . that there is not even a scintilla of proof of any fraud, concealment or deception such as would justify the invocation of the doctrine of estoppel to toll the running of the statute. On the contrary, this record, clearly and distinctly, indicates that [the plaintiffs] slept on their rights and took no steps whatsoever toward the recovery of compensation .... Id.”
1 later decision quote this exact passage“the statute of limitations will run against persons under a disability, including minors, . . . [and] the legislature can at any time, that it seé fit, reestablish an exclusion of persons under disability from the operation of the statute of limitations.”
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.