Vallinoto v. DiSandro’s Empirical Analysis
1997
Citation profile
7 district · 30 state decisions
How this case has been cited
Cited by 38 later decisions — most recently August 2022 · most notably Doe v. Zedek (1999), Swerdlick v. Koch (1998)
7 district · 30 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 Agis v. Howard Johnson Co. · Kazatsky v. King David Memorial Park, Inc. · Wagenmann v. Adams · Solomon v. Aberman · 119 Wash. 2d 251 - Hizey v. Carpenter
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““It has not been enough that the defendant has acted with an intent which is tortious or even criminal, or that he has intended to inflict emotional distress, or even that his conduct has been characterized by ‘malice,’ or a degree of aggravation which would entitle the plaintiff to punitive damages for another tort. Liability has been found only where the conduct has been so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community. Generally, the ease is one in which the recitation of the facts to an average member of the community would arouse his resentment against the actor, and lead him to exclaim, ‘Outrageous!’” Restatement (Second) Torts, § 46 cmt. d, at 73 (Emphasis added.)”
2 later decisions quote this exact passage · from the dissent“"Violation of a Rule should not give rise to a cause of action nor should it create any presumption that a legal duty has been breached. The Rules are designed to provide guidance to lawyers and to provide a structure for regulating conduct through disciplinary agencies. They are not designed to be a basis for civil liability."”
1 later decision quote this exact passage · from the majority““absent the close working relationship between the social worker in that case and the physician, and the physician’s supervision involved therein, the social worker would not have been able to testify concerning the psychotherapy sessions in such detail * * Vallinoto, 688 A.2d at 840 .”
1 later decision 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.