Steele v. United States’s Empirical Analysis
599 F.2d 823 · 1979
Citation profile
26 federal appellate · 3 district · 5 state decisions
How this case has been cited
Cited by 60 later decisions — most recently July 2008 · most notably Barrett v. United States (1982), Dyniewicz v. United States (1984)
26 federal appellate · 3 district · 5 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
Applies 28 U.S.C. § 1346 (Federal Tort Claims Act) · 28 U.S.C. § 2401 · 28 U.S.C. § 2675
Relies on Urie v. Thompson · Douglas v. Alabama · Order of Railroad Telegraphers v. Railway Express Agency, Inc. · Bialowas v. United States · Quinton v. United States
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the nature of the tort itself and the character of the injury will frequently prevent knowledge of what is wrong, so that the plaintiff is forced to rely upon what he is told by the physician.”
2 later decisions quote this exact passage · from the majority“The bar to the plaintiffs action appears not so much the result of the accrual of his cause of action when he suffered the injury, as his waiting until the last minute to take action and his confusion about the proper means of commencing a tort claim against the United States. The two-year limitations period was intended to afford those injured by torts committed by agents of the government a reasonable time to discover the facts, seek legal advice, and prepare their claims. The reasonable inference to be drawn from the history of the plaintiff’s claim is that he did not use this time diligently.”
1 later decision quote this exact passage · from the majoritye.g. Wollman v. Gross“Regardless of the correctness of the relaxed discovery rule in medical malpractice cases, we do not believe that the refinement of the discovery rule should govern when a claim accrues for a more ordinary tort such as the one suffered by the plaintiff here. . . The governing rule is that when the injury coincides with the negligent act and some damage is discernible at that time, the cause of action accrues and the statute of limitations begins to run immediately. Because the injury is apparent, it is the duty of the victim of the tort to discover the negligent acts and file a claim. . .”
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.