494 So. 2d 31 - Webster v. Byrd’s Empirical Analysis
1986
Citation profile
21 state decisions
How this case has been cited
Cited by 24 later decisions — most recently April 2019
21 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 Dann v. Johnston · Addington v. Texas · Paxman v. Henrico County School Board · Green Acres Trust v. London · Elder v. Holland
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“' " 'Where a party makes a communication, and such communication is prompted by duty owed either to the public or to a third party, or the communication is one in which the party has an interest, and it is made to another having a corresponding interest, the communication is privileged, if made in good faith and without actual malice. * * * The duty under which the party is privileged to make the communication need not be one having the force of legal obligation, but it is sufficient if it is social or moral in its nature and defendant in good faith believes he is acting in pursuance thereof, although in fact he is mistaken.' " " Willis v. Demopolis Nursing Home, Inc. , 336 So.2d 1117 , 1120 (Ala. 1976), quoting from Berry v. City of New York Insurance Co. , 210 Ala. 369 , 371 , 98 So. 290 , 292 (1923).”
6 later decisions quote this exact passage“"This Court has held that tenure hearings are quasi-judicial in nature, State Tenure Commission v. Madison County Board of Education , 282 Ala. 658 , 213 So.2d 823 (1968); Board of Education of Choctaw County v. Kennedy , 256 Ala. 478 , 55 So.2d 511 (1951); State v. Board of Education of Fairfield , 252 Ala. 254 , 40 So.2d 689 (1949), but this Court has never decided, until today, whether communications made in the course of quasi-judicial proceedings are absolutely privileged. We came near to expressing an opinion in this matter with our decision in Dunning v. Boyes , 351 So.2d 883 (Ala. 1977), cert. den., 436 U.S. 917 [ 98 S.Ct. 2261 , 56 L.Ed.2d 757 ] (1978), where we held that defamatory communications made in the course of grievance proceedings under collective bargaining contracts are only conditionally privileged, but that case was expressly overruled in Surrency v. Harbison , 489 So.2d 1097 (Ala. 1986), where this Court held that an alleged statement made in the course of a grievance hearing is absolutely privileged. The courts are divided as to whether an absolute privilege attaches to communications made in the course of quasi-judicial proceedings. Some courts recognize only a conditional privilege. Gardner v. Hollifield , 97 Idaho 607 , 549 P.2d 266 (1976); Elder v. Holland , 208 Va. 15 , 155 S.E.2d 369 (1967). The majority view, and the view we now adopt, is that an absolute privilege attaches to communications made in the course of quasi-judicial proceedings. Bru”
5 later decisions quote this exact passage“[w]hether a communication is privileged by reason of its character or the occasion on which it was made is a question of law for the judge.”
5 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.