Biro v. Hirsch’s Empirical Analysis

Citation profile

6 district · 40 state decisions

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 46 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Stated simply, to substantiate a claim of tortious interference with a business expectancy, there must be evidence that the interference resulted from the defendant's commission of a tort.”

   3 later decisions quote this exact passage
   e.g. Zamstein v. Anthem Blue Cross B.S., No. Cv 01-0809618s (Sep. 12, 2002) · Handex Environmental, Inc. v. Hardman, No. Cv01 016 64 62 (Nov. 18, 2002)

2. “For [a party] to prevail on a claim of intentional infliction of emotional distress, four elements must be established. It must be shown: (1) that the actor intended to inflict emotional distress or that he knew or should have known that emotional distress was the likely result of his conduct; (2) that the conduct was extreme and outrageous; (3) that the . . . conduct was the cause of the [party's] distress; and (4) that the emotional distress sustained by the [party] was severe. . . . Liability for intentional infliction of emotional distress requires conduct exceeding all bounds usually tolerated by decent society, of a nature which is especially calculated to cause, and does cause, mental distress of a very serious kind.”

   2 later decisions quote this exact passage
   e.g. 2001 Conn. Super. Ct. 15292 - Carnemolla v. Walsh, No. Cv99-0155192s (Nov. 8, 2001) · 2001 Conn. Super. Ct. 12655 - McNamara v. Tournament Players Club, No. Cv-00-0093091 (Sep. 4, 2001)

3. “An action for tortious interference with a business expectancy is well established in Connecticut. The plaintiff need not prove that the defendant caused the breach of an actual contract; proof of interference with even an unenforceable promise is enough . . . A cause of action for tortious interference with a business expectancy requires proof that the defendant was guilty of fraud, misrepresentation, intimidation or molestation . . . or that the defendant acted maliciously . . . It is also true, however, that not every act that disturbs a contract or business expectancy is actionable . . . A defendant is guilty of tortious interference if he has engaged in improper conduct . . . [T]he plaintiff [is required] to plead and prove at least some improper motive or improper means.”

   1 later decision quote this exact passage
   e.g. Zamstein v. Anthem Blue Cross B.S., No. Cv 01-0809618s (Sep. 12, 2002)