Gates v. Richardson’s Empirical Analysis
1986
Citation profile
3 federal appellate · 2 district · 91 state decisions
How this case has been cited
Cited by 100 later decisions (1 by the Supreme Court) — most recently February 2025 · most notably Atchison Topeka and Santa Fe Railway Company v. Buell (1987), 48 Cal. 3d 644 - Thing v. La Chusa (1989)
3 federal appellate · 2 district · 91 state decisions — followed in 21 states
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 Linkletter v. Walker · Chevron Oil Co. v. Huson · Hanover Shoe, Inc. v. United Shoe MacHinery Corp. · Allen v. State Board of Elections · Nehring v. Russell
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 100 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““To summarize all of our limitations on this tort [negligent infliction of emotional distress], we hold that the class of plaintiffs who may bring an action for negligent infliction of emotional distress consists of those who could bring, at least under some set of circumstances, a wrongful death action for the primary victim’s death. The primary victim must die, or suffer serious bodily injury as that term is defined in the Wyoming Criminal Code. The plaintiff must observe either the infliction of the fatal or harmful blow or observe the results of the blow after its occurrence without material change in the condition and location of the victim. Once these conditions are satisfied, the case can go forward under normal negligence ‘principles. The defendant must have been negligent and his negligence must be the proximate cause of the plaintiffs mental injuries.” Id. at 200-01 (emphasis added).”
3 later decisions quote this exact passage · from the dissent““Outrageous Conduct Causing Severe Emotional Distress “(1) One who by extreme and outrageous conduct intentionally or recklessly causes severe emotional distress to another is subject to liability for such emotional distress, and if bodily harm to the other results from it, for such bodily harm.””
1 later decision quote this exact passage · from the dissent
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.