Bass v. Commonwealth’s Empirical Analysis
1979
Citation profile
2 federal appellate · 242 state decisions
How this case has been cited
Cited by 249 later decisions — most recently January 2026 · most notably Commonwealth v. Revtai (1987), Cook v. Unemployment Compensation Board of Review (1996)
2 federal appellate · 242 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 Smith v. Allwright · Washington v. Washington State Commercial Passenger Fishing Vessel Ass'n · Nixon v. Nixon · West Penn Power Company v. Goddard · Wise v. Cambridge Springs 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 249 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[T]he decisions in the Bass line of cases were limited strictly to the unique and compelling factual circumstances presented to the court, and they were never intended to create, as Justice Roberts warned in his dissenting opinion in Bass , ‘a new and unnecessary layer of delay, mandating a special inquiry whenever an appeal is untimely filed.’”
4 later decisions quote this exact passage · from the dissent“Appellant argues that we should equate the failure to file a timely appeal in this case as “in fact a negligent act of a court official.” Appellant also argues that “mere inadvertence” should not prevent an appellant from access to the appellate process. It is true that in our system of law an attorney, in a sense, serves both as an advocate for his client and as an officer of the court. It has recently been recognized by statutory law that an attorney is a public officer____ We are unable to conclude, however, that the office of attorney is to be equated for all purposes with the term “court officer.” We cannot overlook the fact, however, that an attorney at law, chosen by a client from a limited group of persons legally entitled to represent the client, is an integral and necessary part of our system of justice. To view a citizen’s attorney as a completely non-public officer would be ignoring the reality that our system of justice could not function properly and efficiently without the traditional view that an attorney not only represents a client, but is in a sense an officer of the court. Therefore, at least in those circumstances involving the non-negligent failure to file an appeal, members of the public should not lose their day in court.”
2 later decisions quote this exact passage“non-negligent failure to file a timely appeal ... was corrected within a very short time, during which any prejudice to the other side of the controversy would necessarily be minimal.”
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.