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← 708 A.2d 1269 - Hennessy v. Santiago

Hennessy v. Santiago’s Empirical Analysis

1998

Citation profile

32
cited by 32 later decisions
1
states following
September 2021
most recently cited

2 federal appellate · 14 state decisions

How this case has been cited

Cited by 32 later decisions — most recently September 2021 · most notably Fraser v. Nationwide Mutual Insurance (2003), 2003 Pa. Super. 353 - Reading Radio, Inc. v. Fink (2003)

2 federal appellate · 14 state decisions

1701998200020102020decided

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))

Relies on Monell v. Department of Social Services of City of New York · Adickes v. S. H. Kress & Co. · City of Canton v. Harris · Pembaur v. City of Cincinnati · Board of the County Commissioners of Bryan County v. Brown

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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “[A]n employer (1) cannot require an employee to commit a crime [and fire the employee for refusing to do so], (2) cannot prevent an employee from complying with a statutorily imposed duty, and (3) cannot discharge an employee when specifically prohibited from doing so by statute.”
    4 later decisions quote this exact passage
  2. “There are four elements to this cause of action: (1)the existence of a contractual relationship; (2) an intent on the part of the defendant to harm the plaintiff by interfering with that contractual relationship; (3) the absence of a privilege or justification for such interference; and (4) damages resulting from the defendant’s conduct. Triffin v. Janssen, 426 Pa.Super. 57 , 626 A.2d 571, 574 (1993). The problem for appellant is that, absent a contract, employees in Pennsylvania are considered to be at-will. Therefore, they can be terminated at any time for any reason. Stumpp v. Stroudsburg Mun. Auth., 540 Pa. 391, 396 , 658 A.2d 333, 335 (1995). In her second amended complaint, appellant does not allege that she was a contractual employee. Instead, she attempts to bring herself within the ambit of Yaindl v. Ingersoll-Rand Co., 281 Pa.Super. 560 , 422 A.2d 611 (1980). In Yaindl , a panel of this court held that a cause of action exists where a person intentionally and improperly interferes with “another’s prospective contractual relation.” Id., 422 A.2d at 624 (emphasis added). Moreover, that interference must induce or cause a third person not to enter into the prospective relationship. Id. Appellant recognizes that Albert did not interfere with any prospective contractual relationship between Santiago and herself. Instead, she relies upon language found in footnote six of Yaindl : “Of course, an action for intentional interference with the performance of a contract lies ev”
    1 later decision quote this exact passage
  3. “test as one of several paradigms of state action by a private individual developed by United States Supreme Court jurisprudence). Appellant maintains that,”
    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.