Washington v. Baxter’s Empirical Analysis
1998
Citation profile
102 state decisions
How this case has been cited
Cited by 104 later decisions — most recently May 2025 · most notably LJL Transportation, Inc. v. Pilot Air Freight Corp. (2009), Weaver v. Lancaster Newspapers, Inc. (2007)
102 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 Commonwealth v. Stoltzfus · Marks v. Tasman · Phillips v. A-Best Products Co. · Kemmerer v. Commonwealth, Department of Transportation, Bureau of Driver Licensing · In re Ashley
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 104 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The ‘serious impairment of body function’ threshold contains two inquiries: “(a) What body function, if any, was impaired because of injuries sustained in a motor vehicle accident? “(b) Was the impairment of the body function serious? The focus of these inquiries is not on the injuries themselves, but on how the injuries affected a particular body function. Generally, medical testimony will be needed to establish the existence, extent, and permanency of the impairment. ... In determining whether the im pairment was serious, several factors should be considered: the extent of the impairment, the length of time the impairment lasted, the treatment required to correct the impairment, and any other relevant factors. An impairment need not be permanent to be serious.””
2 later decisions quote this exact passage · from the dissent““[T]hat [the plaintiff] was immediately treated [after the accident] in a hospital emergency room, where his injuries were diagnosed as consisting of contusions, sprains, and strains; he was discharged from the emergency room within a few hours. He missed four or five days of work at his full-time job, and missed approximately four of his weekly shifts at his part-time job. Approximately six months after the accident, one of [the plaintiff’s] physicians stated that there appeared to be some type of joint arthritis or coalition in the right foot, and that [the plaintiff] might need to utilize orthotic heel lifts; his physician also injected one shot of cortisone.”
1 later decision quote this exact passage · from the dissent“as with all summary judgment cases, we must view the record in the light most favorable to the non-moving party, and all doubts as to the existence of a genuine issue of material fact must be resolved against the moving party”
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.