Flowers v. Walker’s Empirical Analysis
1992
Citation profile
10 federal appellate · 163 state decisions
How this case has been cited
Cited by 193 later decisions — most recently October 2025 · most notably 124 Ohio App. 3d 581 - Zemcik v. LaPine Truck Sales & Equipment Co. (1998), 92 Ohio App. 3d 443 - Craggett v. Adell Insurance Agency (1993)
10 federal appellate · 163 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 Oliver v. Kaiser Community Health Foundation · Allenius v. Thomas · Hershberger v. Akron City Hospital · 128 Cal. App. 3d 965 - Graham v. Hansen · 97 Cal. App. 3d 798 - McGee v. Weinberg
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 193 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[C]onstructive knowledge of facts, rather than actual knowledge of their legal significance, is enough to start the statute of limitations running under the discovery rule.”
22 later decisions quote this exact passage““In a medical malpractice case, the statute of limitations starts to run upon the occurrence of a ‘cognizable event.’ The occurrence of a ‘cognizable event’ imposes upon the plaintiff the duty to (1) determine whether the injury suffered is the proximate result of malpractice and (2) ascertain the identity of the tortfeasor or tortfeasors.””
5 later decisions quote this exact passage“'cognizable event' is the occurrence of facts and circumstances which lead, or should lead, the patient to believe that the physical condition or injury of which she complains is related to a medical diagnosis, treatment, or procedure that the patient previously received.”
2 later decisions quote this exact passage
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.