Williams v. McClain’s Empirical Analysis
1987
Citation profile
42 state decisions
How this case has been cited
Cited by 42 later decisions — most recently March 2019 · most notably 441 Pa. Super. 1 - Sprague v. Walter (1995), 415 Pa. Super. 41 - Primavera v. Celotex Corp. (1992)
42 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 336 Pa. Super. 22 - Dambacher by Dambacher v. Mallis · Anderson v. Hughes · Paxos v. Jarka Corporation · Jones Appeal · Commonwealth v. DiGiacomo
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 42 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A record of an act, condition or event shall, insofar as relevant, be competent evidence if the custodian or other qualified witness testifies to its identity and the mode of its preparation, and if it was made in the regular course of business at or near the time of the act, condition or event, and if, in the opinion of the tribunal, the sources of information, method and time of preparation were such as to justify its admission.”
3 later decisions quote this exact passage · from the majority“... These three factors are helpful in determining whether a business record is admissible. A report that contains nothing but facts, and meets this three part test may be admissible under the Business Records Act. Simply meeting these three factors, however, does not guarantee the admissibility of a record under the Business Records Act ... ... Under this exception, hospital records have been admitted to show the fact of hospitalization, treatment prescribed and symptoms found. Commonwealth v. DiGiacomo, 463 Pa. 449 , 345 A.2d 605 (1975); Platt v. John Hancock Mutual Life Insurance Company, 361 Pa. 652 , 66 A.2d 266 (1949). As Superior Court noted in Commonwealth v. Seville, 266 Pa.Superior Ct. 587, 405 A.2d 1262 (1979): No such doubt as to reliability and accuracy are entertained when a record is offered merely to prove facts, such as the event of hospitalization, treatment prescribed, symptoms given, or the existence of some readility ascertained substance or chemical within the body. Id., 266 Pa.Superior Ct. at 592, 405 A.2d at 1264 . This Court, however, has consistently held that opinion evidence contained in hospital records is inadmissible. Commonwealth v. DiGiacomo, supra; Jones Appeal, 419 Pa. 543 , 297 A.2d 117 (1972); see also Morris v. Moss, 290 Pa.Superior Ct. 587, 593, 435 A.2d 184, 187 (1981). (opinion that person is conscious is not fact free from doubt) (Williams, supra, at pp. 305-306 )”
1 later decision quote this exact passage · from the majority“Not all trial errors rise to the level of reversible error. An erroneous ruling must also be harmful to the complaining party before reversal is required. Anderson v. Hughes, 417 Pa. 87 , 208 A.2d 789, 791 (1965). Upon a proper consideration of the record we hold that the social worker’s report related to the liability issue of causation, as well as damages, and so was harmful to Williams. To prove her case Williams had to show that McClain’s negligence was the proximate cause of her injuries. Based on the social worker’s opinion, it is possible that the jury found that these injuries would have existed with or without negligence on the part of McClain.”
1 later decision 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.