Strunk v. Zoltanski’s Empirical Analysis
1984
Citation profile
4 federal appellate · 75 state decisions
How this case has been cited
Cited by 82 later decisions — most recently August 2023 · most notably Gallose v. Long Island Railroad (1989), Stokes v. Lyddy (2003)
4 federal appellate · 75 state decisions — followed in 15 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.
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 82 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Considerations of public policy require that a landlord who, prior to leasing the premises, has knowledge that the tenant may be expected to carry on activities on the premises in such a manner as unreasonably to expose third persons to risk of physical , injury has a duty to take such precautions as lie within the control of the landlord reasonably to protect such third persons from the injuries to be foreseen if no such precautions are taken.””
3 later decisions quote this exact passage · from the majority“A lessor of land is subject to liability for physical harm to persons outside of the land caused by activities of the lessee or others on the land after the lessor transfers possession if, but only if, (a) the lessor at the time of the lease consented to such activity or knew that it would be carried on, and (b) the lessor knew or had reason to know that it would unavoidably involve such an unreasonable risk, or that special precautions necessary to safety would not be taken.”
2 later decisions quote this exact passage · from the majority““by leasing the premises to the owner of the dog, [the landlord] could be found to affirmatively have created the very risk which was reasonably foreseeable and which operated to injure plaintiff.””
2 later decisions 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.