King v. Kidd’s Empirical Analysis
1993
Citation profile
4 federal appellate · 42 district · 28 state decisions
How this case has been cited
Cited by 78 later decisions — most recently March 2019 · most notably 938 F. Supp. 46 - Williams v. Callaghan (1996), Homan v. Goyal (1998)
4 federal appellate · 42 district · 28 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 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act)) · 42 U.S.C. § 2000E (§ 701 of the Title VII of the Civil Rights Act of 1964)
Relies on United Mine Workers of America v. Gibbs · Meritor Savings Bank, FSB v. Vinson · Henson v. City of Dundee · Fields v. Hartford Casualty Insurance Co. · Innkeepers of New Castle, Inc. v. Maley
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 78 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“After reviewing the purposes and text of the CMPA, ... we find no basis to conclude that CMPA’s remedial system preempts Kidd’s tort claim of intentional infliction of emotional distress based on acts of sexual harassment and subsequent retaliation____ Although the jurisdictional issue appellants raise concerns Kidd’s common law claim and not her related Title VII sex discrimination claim, we think the exclusion of sexual harassment claims from CMPA Subchapters 15 and 17 is persuasive evidence that appellee’s tort claim— fundamentally linked to her sexual harassment claim—is not cognizable as a “personnel issue” under the Act’s “performance ratings,” “adverse actions,” and employee “grievances” provisions.... Kidd’s claim for intentional infliction of emotional distress had an inherent “nexus” to her sexual harassment claim, “a subject matter within the responsibility of a division of the Superior Court,” and it was therefore proper for the court to “rely upon its general powers in accepting jurisdiction over the claim.””
2 later decisions quote this exact passage · from the concurrence“There are two primary components of “extreme and outrageous conduct” we must consider: (1) applicable contemporary community standards of offensiveness and decency, and (2) the specific context in which the conduct took place ... The court, in determining whether the conduct is outrageous, should first consider the nature of the activity. “The extreme and outrageous character of the conduct may arise from an abuse by the actor of a position, or a relation with the other, which gives him [or her] actual or apparent authority over the other, or power to affect his [or her] interests.” Restatement (Second) of Torts § 46 cmt. e.”
1 later decision quote this exact passage · from the concurrence“Maury criticized her in memorandum after memorandum; he approved her leave and then changed her status to absence without leave; he refused to consider her for promotion to the next grade level or to give her the computer test she asked for; he isolated her from the other employees; he requested statements from her doctor as to her limited hours; he wrote memoranda on her excessive leave; and he assaulted her and lied about it, resulting in her job loss.”
1 later decision 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.