Criss v. Wise’s Empirical Analysis
2001
Citation profile
2 federal appellate · 73 state decisions
How this case has been cited
Cited by 75 later decisions — most recently June 2025 · most notably Arena Beverage Corp. v. Pennsylvania Liquor Control Board (2014), 2013 Pa. Super. 14 - Weston v. Northampton Personal Care, Inc. (2013)
2 federal appellate · 73 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 Bass v. Commonwealth · West Penn Power Company v. Goddard · Cook v. Unemployment Compensation Board of Review · Commonwealth v. Stock · James F. Oakley, Inc. v. Sch. Dist. of Phila.
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 75 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the appellant's notice of appeal was filed late as a result of non-negligent circumstances, either as they relate to the appellant or the appellant’s counsel; (2) the appellant filed the notice of appeal shortly after the expiration date; and (3) the appellee was not prejudiced by the delay.” Id.”
9 later decisions quote this exact passage · from the majority“In order to perfect an appeal, parties must strictly adhere to the statutory provisions for filing an appeal_ Unlike the Rules of Appellate Procedure, which in certain instances specify that filings can be deemed filed on the date they are deposited in the U.S. Mail, the Pennsylvania Rules of Civil Procedure do not so provide. In fact, Rule of Civil Procedure 205.1 specifically provides that “[a] paper sent by mail shall not be deemed filed until received by the appropriate officer.” Pa.R.C.P. 205.1. Moreover, appellate courts do not have the authority to enlarge the time for filing a notice of appeal. Pa.R.A.P. 105. Therefore, as Rule 1308 [governing appeals from arbitration awards] now stands, for an appeal from an arbitration award to be deemed timely filed, the prothonotary of the court where the action is pending must receive a notice of appeal within thirty days from the date the prothonotary notes on the docket that the arbitration award has been entered and the parties have been notified of the award.”
2 later decisions quote this exact passage · from the majority“The exception for allowance of an appeal nunc pro tunc in non-negligent circumstances is meant to apply only in unique and compelling cases in which the appellant has clearly established that she attempted to file an appeal, but unforeseeable and unavoidable events precluded her from actually doing so. See Cook, 671 A.2d at 1132; Perry v. Unemployment Comp. Bd. of Review, [ 74 Pa.Cmwlth. 388 , 459 A.2d 1342, 1343 (1983)] (fact that law clerk’s car broke down while he was on route to the post office, precluding him from getting to the post office before closing time, was a non-negligent happenstance for granting appeal nunc pro tunc); Tony Grande, Inc. v. Workmen’s Compensation Appeal Bd. (Rodriquez), [ 71 Pa.Cmwlth. 566 , 455 A.2d 299, 300 (1983)] (hospitalization of appellant’s attorney for unexpected and serious cardiac problems ten days into twenty day appeal period was reason to allow appeal nunc pro tunc); Walker v. Unemployment Comp. Bd. of Review, [ 75 Pa.Cmwlth 116 , 461 A.2d 346, 347 (1983)] (U.S. Postal Service’s failure to forward notice of referee’s decision to appellant’s address, as appellant had requested, warranted appeal nunc pro tunc)....”
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.