71 N.C. App. 556 - Sawyer v. Carter’s Empirical Analysis
1984
Citation profile
3 federal appellate · 28 state decisions
How this case has been cited
Cited by 41 later decisions — most recently March 2019 · most notably Murrow v. Daniels (1988), 641 So. 2d 1186 - Crain v. Cleveland Lodge 1532, Order of Moose, Inc. (1994)
3 federal appellate · 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
Relies on Scott v. Watson · Foster v. Winston-Salem Joint Venture · Cornpropst v. Sloan · 52 N.C. App. 428 - Loy v. Lorm Corp. · 41 N.C. App. 107 - Best v. Perry
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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We doubt there exists a community in this State which is entirely crime-free. In the broadest sense, all crimes anywhere are "foreseeable." To impose a blanket duty on all merchants to afford protection to their patrons would be a result not intended by our courts and not condoned by public policy. Discharging such a duty would undoubtedly be inconvenient and expensive, and to impose a duty absent true foreseeability of criminal activity in a particular store would be grossly unfair.”
2 later decisions quote this exact passage“evidence pertaining to the foreseeability of criminal attack shall not be limited to prior criminal acts occurring on the premises,”
2 later decisions quote this exact passage“We said in Sawyer : [E]vidence of similar prior criminal activity committed on the premises is the most strongly probative type of evidence on the question of foreseeability. . . . . . . The forecast of evidence in this case does not support a triable issue of fact on the question of reasonable foreseeability.”
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.