Seal v. Safeway Stores, Inc.’s Empirical Analysis
1944
Citation profile
48 state decisions
How this case has been cited
Cited by 50 later decisions — most recently December 1993 · most notably 30 Cal. 3d 721 - Marina Point, Ltd. v. Wolfson (1982), Mahoney v. JC Penney Company (1962)
48 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 Matson v. Tip Top Grocery Company, Inc. · Mesich v. Board of County Com'rs of McKinley Co. · Fitzsimmons Ex Rel. Fitzsimmons v. Missouri Pacific Railroad · Lehner v. Roth · Snodgrass v. Turner Tourist Hotels, Inc.
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 50 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Counsel for plaintiff, if we correctly appraise their position, concede it to be a well established rule of law that it is not negligence to maintain, under appropriate circumstances, different levels in approaches to such places of business, or even within such stores ; and they are correct in this assumption. The rule is very well established both as to change of elevations and use of stairways. See Watkins v. Piggly Wiggly Bird Co., 8 Cir., 31 F.2d 889 ; Boyle v. Preketes, 262 Mich. 629 , 247 N.W. 763 ; Albachten v. Golden Rule, 135 Minn. 381 , 160 N.W. 1012 ; Dickson v. Emporium Merc. Co., 193 Minn. 629 , 259 N.W. 375 ; Haddon v. Snellenburg, 293 Pa. 333 , 143 A. 8 ; Main v. Lehman, 294 Mo. 579 , 243 S.W. 91 ; Matson v. Tip Top Groc. Co., 151 Fla. 247 , 9 So.2d 366 . * * * * * * “The drop in elevation of some 3 or 4 inches from the paved walk to the paved parking space, where plaintiff was walking at the time of the accident, cannot be said to present a hidden or concealed danger for any person using it in broad daylight especially, and keeping a reasonable watch as to where he is walking, and with no unreasonable distractions. Certainly plaintiff, upon entering or leaving a store of this character, and undertaking to walk through and upon the parking grounds, must take notice that such changes in elevations are not uncommon and are to be expected. “Likewise she is not to be absolved from the exercise of reasonable watchfulness as to where she is placing her feet simply ”
3 later decisions quote this exact passage““If it could be said that negligence could be charged to defendant in the ■ maintenance of this particular facility of ingress and egress, it would be difficult to imagine a case where different elevations about store entrances could be reasonably employed without incurring liability for negligence.””
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.