Madler v. McKenzie County’s Empirical Analysis
1991
Citation profile
3 federal appellate · 1 district · 14 state decisions
How this case has been cited
Cited by 20 later decisions — most recently April 2024
3 federal appellate · 1 district · 14 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 Douglas v. Alabama · Corsetti v. Stone Co. · 10 Ill. App. 3d 625 - Weber v. Northern Illinois Gas Co. · Valdez v. Cillessen & Son, Inc. · 14 Ill. App. 3d 481 - Pasko v. Commonwealth Edison 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.
““§ 414. Negligence in Exercising Control Retained by Employer “One who entrusts work to an independent contractor, but who retains the control of any part of the work, is subject to liability for physical harm to others for whose safety the employer owes a duty to exercise reasonable care, which is caused by his failure to exercise his control with reasonable care.””
4 later decisions quote this exact passage“'[a]n employer who does not retain or actually exercise any control over a project of the employees of an independent contractor, but, instead, is concerned primarily only with the finished product should not be held liable for the negligence of the independent contractor or its employees.'”
4 later decisions quote this exact passage“"If McKenzie County exercised some control over the manner in which the contractor’s work was being performed or provided supervision at the worksite so that Schwartz was not entirely free to do the work in its own way, then McKenzie County incurred a duty of care toward Madler under the principle stated in Section 414. This is a factual question about which reasonable persons could differ, and, therefore, it should be submitted to the jury.””
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.