Paugh v. Hanks’s Empirical Analysis
1983
Citation profile
33 federal appellate · 4 district · 385 state decisions
How this case has been cited
Cited by 595 later decisions (2 by the Supreme Court) — most recently July 2025 · most notably Consolidated Rail Corporation v. Gottshall (1994), Clohessy v. Bachelor (1996)
33 federal appellate · 4 district · 385 state decisions — followed in 20 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
Relies on Palsgraf v. Long Island R.R. Co. · Dillon v. Legg · Strother v. Hutchinson · 27 Cal. 3d 916 - Molien v. Kaiser Foundation Hospitals · Sinn v. Burd
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 595 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“serious emotional distress may be found where a reasonable person, normally constituted, would be unable to cope adequately with the mental distress engendered by the circumstances of the case.”
67 later decisions quote this exact passage · from the dissent““[Expert] medical testimony can assist the judicial process in determining whether the emotional injury is indeed, serious * * *. However, lay witnesses who were acquainted with the plaintiff, may testify as to any marked changes in the emotional or habitual makeup that they discern in the plaintiff after the accident has occurred. The jurors themselves, can refer to their own experiences in order to determine whether, and to what extent, the defendant’s conduct caused the serious emotional distress.” (Citation omitted.) Paugh v. Hanks (1983), 6 Ohio St.3d 72, 80 , 6 OBR 114, 121, 451 N.E.2d 759, 767 .”
5 later decisions quote this exact passage · from the dissent“`We decline to draw an absolute boundary around the class of persons whose peril may stimulate the mental distress. This usually will be a jury question bearing on the reasonable reaction to the event. . . .'”
2 later decisions quote this exact passage · from the dissent
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.