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← 455 NW2D 580 - Thompson v. Goetz

Thompson v. Goetz’s Empirical Analysis

1990

Citation profile

34
cited by 34 later decisions
2
states following
January 2026
most recently cited

33 state decisions

How this case has been cited

Cited by 34 later decisions — most recently January 2026 · most notably 120 Wash. 2d 246 - Washburn v. Beatt Equipment Co. (1992), Sargent County Bank v. Wentworth (1993)

33 state decisions

2201990200020102020decided

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 Bon Air Hotel, Inc. v. Time, Inc. · Greene v. Union Mutual Life Insurance Co. of America · Olson v. Fraase · Peterson v. Zerr · Security General Life Insurance v. Superior Court

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

  1. “the finding of fact as to the value of goods and services is not supported by sufficient evidence and rests merely on the assertion made in the counterclaim. Even in situations where a court has entered default, it is necessary for the nondefaulting party to submit an affidavit in support of a sum certain or, in all other cases, such proof as may be necessary to enable the court to determine and grant the relief, if any, to which the nondefaulting party may be entitled. Rule 55(a), N.D.R.Civ.P. An entry of summary judgment for a particular amount without sufficient evidence supporting that amount is erroneous.”
    1 later decision quote this exact passage
  2. “(a) A lawyer shall not act as advocate at a trial in which the lawyer is likely to be a necessary witness except where: (1) the testimony relates to an uncontested issue; (2) the testimony relates to the nature and value of legal services rendered in the case; or (3) disqualification of the lawyer would work substantial hardship on the client.”
    1 later decision quote this exact passage
  3. ““Under Rule 54(b), if some claims or issues ... remain unadjudicated, the trial court must certify that there is no just reason for delay and direct the entry of a final judgment for the order to be appealable. In the absence of a Rule 54(b) certification, we are without jurisdiction to consider the appeal.””
    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.