Croce v. Hall’s Empirical Analysis
1995
Citation profile
3 federal appellate · 5 district · 12 state decisions
How this case has been cited
Cited by 23 later decisions — most recently March 2018
3 federal appellate · 5 district · 12 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 LaCourse v. Fleitz · Ralph D. Smith and Thelma Smith v. Arbaugh's Restaurant, Inc., a Body Corporate · Pessagno v. Euclid Inv. Co. · Langley Park Apartments, SEC. H., Inc. v. Lund · Spar v. Obwoya
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“... I think the Croce case requires that judgment as a matter of law be granted to the defendants. First of all, at the time of the accident in question it was still snowing. That’s the testimony of both Mrs. Youssef and her husband. And essentially the Croce case, first of all, says that a landlord without actual knowledge of the existence of dangerous conditions ordinarily has a reasonable time after the conclusion of the storm to remove any hazardous accumulation of snow and ice. Again, on page 311 the Croce case quotes favorably from a case in Indiana. It says, “A landlord had no duty to remove the ice during the time moisture was falling and freezing on the ground.” So first of all, under the Croce case, there was no duty on the landlord’s part, on the defendant’s part, to take any action, any remedial measures during the time the snow was falling. Secondly, there was no evidence whatsoever that the defendant had actual notice of any icy or hazardous conditions on the mat with respect to any constructive notice. Again, under Croce there was no requirement for the landlord to start removing anything, and secondly, neither Mrs. Youssef nor Mr. Youssef noticed anything when they were on the mat, when they were walking across the mat. And the only time that this very thin patch of ice was even found was when Mr. and Mrs. Youssef actually touched it. So in terms of its visibility, in terms of any sort of constructive notice, I don’t think a case has been made. I know Mrs. You”
1 later decision quote this exact passage“In general, changes in the weather are a part of everyday life, and citizens can be expected to adjust to them without demanding extraordinary efforts on the part of others. Furthermore, as appellee points out, weather predictions are often wrong, and may vary depending on the identity of the forecaster.... [Weather] reports are competent to prove weather conditions in the locality but, standing alone, they cannot establish the required notice to the [defendant] of the existence of a particular obstruction ... its duration, or its dangerous character.”
1 later decision quote this exact passage“negligence is predicated on a dangerous condition, the plaintiff must show that the defendant had actual or constructive notice of the dangerous condition.”
1 later decision 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.