Hamil v. Bashline’s Empirical Analysis
1978
Citation profile
35 federal appellate · 12 district · 499 state decisions
How this case has been cited
Cited by 667 later decisions — most recently September 2025 · most notably Brown v. Southeastern Pennsylvania Transportation Authority (1994), Feld v. Merriam (1984)
35 federal appellate · 12 district · 499 state decisions — followed in 30 states
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 Cooper v. Sisters of Charity of Cincinnati, Inc. · Whitner v. Lojeski · Majors v. Brodhead Hotel · Hicks v. United States · FLICKINGER ESTATE v. Ritsky
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 667 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“One who undertakes, gratuitously or for consideration, to render services to another which he should recognize as necessary for the protection of the other’s person or things, is subject to liability to the other for physical harm resulting from his failure to exercise reasonable care to perform his undertaking, if (a) his failure to exercise such care increases the risk of such harm, or (b) the harm is suffered because of the other’s reliance upon the undertaking.”
63 later decisions quote this exact passage · from the majority“(1) that the medical practitioner owed a duty to the patient, (2) that the practitioner breached that duty. (3) that that breach was a proximate cause of, or a substantial factor in, bringing about the harm suffered by the patient, and (4) that the damages suffered by the patient were a direct result of the harm.”
10 later decisions quote this exact passage · from the majority“Proximate cause is a term of art, and may be established by evidence that a defendant’s negligent act or failure to act was a substantial factor in bringing about the harm inflicted upon a plaintiff. Pennsylvania law has long recognized that this substantial factor need not be ... the only factor....”
10 later decisions 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.