Adams v. State’s Empirical Analysis
1976
Citation profile
5 federal appellate · 2 district · 114 state decisions
How this case has been cited
Cited by 130 later decisions — most recently May 2025 · most notably Gordon v. Bridgeport Housing Authority (1988), Shore v. Town of Stonington (1982)
5 federal appellate · 2 district · 114 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
Applies 28 U.S.C. § 2674
Relies on Dalehite v. United States · Indian Towing Company v. United States · Palsgraf v. Long Island R.R. Co. · 69 Cal. 2d 782 - Johnson v. State of California · 55 Cal. 2d 211 - Muskopf v. Corning Hospital District
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 130 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“in reality, a form of sovereign immunity.”
17 later decisions quote this exact passage“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.”
5 later decisions quote this exact passage · from the dissent“[N]o action may be brought under this section if the claim (1) . .. is an action for tort, and based upon the exercise or performance or the failure to exercise or perform a discretionary function or duty on the part of a state agency or an employee of the state, whether or not the discretion involved is abused ....”
4 later decisions quote this exact passagee.g. Jennings v. State · State v. Morris
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.