Craft v. Scaman’s Empirical Analysis
1986
Citation profile
28 state decisions
How this case has been cited
Cited by 29 later decisions — most recently May 2014 · most notably Tauchert v. Boatmen's National Bank of St. Louis (1993), Gerrish v. Savard (1999)
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 Athas v. Hill · 61 Wis. 2d 421 - Kruse v. Schieve · State Ex Rel. Badami v. Gaertner · Parmer v. Bean · Neal v. Oliver
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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“required to impose tort liability includes any affirmative act, taken while the officer is acting outside the scope of the employer's responsibility, that breaches a personal duty of care the officer owes to a fellow employee. In the instant case, the averments in plaintiff's petition indicated that defendant's affirmative act had caused or increased the risk of the plaintiff's injury. Plaintiff alleged that”
2 later decisions quote this exact passage“[T]he "something extra" required to impose tort liability includes any affirmative act, taken while the officer is acting outside the scope of the employer's responsibility, that breaches a personal duty of care the officer owes to a fellow employee. In the instant case, the averments in plaintiff's petition indicated that defendant's affirmative act had caused or increased the risk of the plaintiff's injury. Plaintiff alleged that "defendant negligently and carelessly applied friction to the spinning reel of fuse," thereby cause the fire that injured plaintiff. This act did not involve any general, non-delegable duty of the employer, such as the duty to provide a reasonably safe place to work. Rather, defendant breached his common law duty to exercise reasonable care in handling the fuse. This was a duty owed by one employee to another.”
1 later decision quote this exact passagee.g. Workman v. Vader“... a corporate officer or supervisory employee performs in a dual capacity. He has immunity under the workers’ compensation law where his negligence is based upon a general non-delegable duty of the employer; he does not have immunity where he does an affirmative act causing or increasing the risk of injury. Something ‘extra’ is required upon a breach of his duty of general supervision and safety, for that duty is owed to the employer, not the employee.”
1 later decision quote this exact passagee.g. Gabler v. McColl
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.