Detling v. Chockley’s Empirical Analysis
1982
Citation profile
5 federal appellate · 86 state decisions
How this case has been cited
Cited by 101 later decisions — most recently May 2025 · most notably Moskovitz v. Mt. Sinai Medical Center (1994), Preston v. Murty (1987)
5 federal appellate · 86 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 Leichtamer v. American Motors Corp. · Columbus Finance, Inc. v. Howard · 146 Ohio St. 414 - Saberton v. Greenwald · Rubeck v. Huffman · 10 Ohio St. 275 - Lessee of Sullivant v. Weaver
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 101 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[a]ctual malice, necessary for an award of punitive damages, is (1) that state of mind under which a person's conduct is characterized by hatred, ill will or a spirit of revenge, or (2) a conscious disregard for the rights and safety of other persons that has a great probability of causing substantial harm.”
7 later decisions quote this exact passage · from the majority““Evidence of actual malice, therefore, must be present before a jury question of punitive damages is raised; actual malice may take either the form of the defendant’s express ill will, hatred or spirit of revenge, or the form of reckless, wilful or wanton behavior which can be inferred from surrounding circumstances. In either case, the defendant’s actions must have been ‘intentional and deliberate, or * * * [have] the character of outrage frequently associated with crime.’ * * * “An act of mere negligence does not, of itself, demonstrate the degree of intention and deliberation necessary to raise a question of punitive damages. * * * ‘Something more than the mere commission of a tort is always required for punitive damages. There must be circumstances of aggravation or outrage, such as spite or “malice,” or a fraudulent or evil motive on the part of the defendant, or such a conscious and deliberate disregard of the interests of others that his conduct may be called wilful or wanton. * * * ’ Prosser on Torts (4 Ed.), at pages 9-10.” (Emphasis added.)”
6 later decisions quote this exact passage · from the majority“. . . has been recognized . . . as that of punishing the offending party and setting him up as an example to others that they might be deterred from similar conduct.”
5 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.