Hamilton v. Procon, Inc.’s Empirical Analysis
1969
Citation profile
102 state decisions
How this case has been cited
Cited by 102 later decisions — most recently December 2002 · most notably Leon E. Wintermyer, Inc. v. Workers' Compensation Appeal Board (2002), Pawlosky v. Workmen's Compensation Appeal Board (1987)
102 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 Ciuba v. Irvington Varnish & Insulator Co. · Parks v. Miller Printing MacHine Co. · Good v. Pennsylvania Department of Property & Supplies · 146 Pa. Super. 449 - Royko v. Logan Coal Co. · Rathmell v. Wesleyville Borough
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 102 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““If workmen’s compensation is intended to deal with the problems of the individual worker, then the standards which determine whether he shall recover compensation should also be geared to the individual. Furthermore, it is difficult to determine what amounts to an unusual strain for the members of a given profession. Certainly, in a given profession or occupation different members would be subjected to far different working conditions. Most assuredly, there are many carpenters who have never worked under conditions such as those which led to the decedent’s death. What is more, the industry-wide test is difficult to apply because a given member of a profession may be able to tolerate a greater or lesser amount of strain depending on his age. The decedent was sixty-four when he suffered his fatal attack. What is an unusual strain for a carpenter sixty-four years of age who had apparently worked many years in more tranquil surroundings may be far different from what would be an unusual strain for a twenty-year old apprentice carpenter. “For these reasons, we hold that the unusual strain doctrine is to be applied according to the work history of the individual involved and not according to the work patterns of his profession in general.” Id. at 98-99 , 252 A.2d at 605 .”
1 later decision quote this exact passage · from the majority““For these reasons, we hold that the unusual strain doctrine is to be applied according to the work history of the individual involved and not according to the work pattern of his profession in general. “However, viewing the record in its entirety, we must come to the conclusion that the overexertion, unusual to the deceased, aggravated deceased’s pre-exist-ing heart disease to the extent that it did cause an ‘accident’ within the statutory meaning.” (Emphasis ours.)”
1 later decision quote this exact passage · from the majority“Under this doctrine there can be no recovery unless the claimant proves that the death or injury resulted from an overexertion or unusual strain encountered in the course of his employment . . . [and] the unusual strain doctrine is to be applied according to the work history of the individual involved and not according to the work pattern of his profession in general.”
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.