DeWald v. State’s Empirical Analysis
1986
Citation profile
59 state decisions
How this case has been cited
Cited by 61 later decisions — most recently November 2025 · most notably Wallace v. Ohio Department of Commerce (2002), Tice v. Cramer (1993)
59 state decisions — followed in 19 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
Applies 42 U.S.C. § 1983 (Civil Rights Act of 1871 / Section 1983 (Ku Klux Klan Act))
Relies on Scheuer v. Rhodes · 371 So. 2d 1010 - Commercial Carrier Corp. v. Indian River Cty. · 74 Wis. 2d 526 - Coffey v. City of Milwaukee · 84 Wash. 2d 239 - King v. City of Seattle · Ryan v. State
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Proximate cause means that the accident or injury must be the natural and probable consequence of the act of negligence. The law does not charge a person with all the consequences of a wrongful act, but ignores remote causes and looks only to the proximate cause.”
2 later decisions quote this exact passage“(a) A governmental entity and its public employees while acting within the scope of duties are granted immunity from liability for any tort except as provided by [this Act].”
2 later decisions quote this exact passage“The liability of a police officer for pursuing a law violator who becomes involved in an accident causing damage to a third person has not before been considered by this court. A review of the decided cases exhibits a considerable reluctance to find the officers liable where they are not involved in the accident. The policy reasons stated are that the officer has a duty to apprehend, arrest and remove from the highways drunk drivers; that if, in the performance of his job as a patrolman, he must choose whether to pursue or allow a lawhreaker to escape, he should not be liable for either choice in the absence of gross or wanton conduct almost amounting to bad faith; that he should be responsible only for the careful operation of his own car; and that he should not be liable for the unpredictable actions of the driver being pursued for that would make him an insurer of the wrongful acts of a lawhreaker. All of the above seem to essentially say that, except in extreme or outrageous cireumstances, an officer's pursuit of a vehicle which is involved in an accident not involving the officer's vehicle is not the proximate cause of that accident. * * * We agree with these courts and hold that when a police officer pursues a fleeing violator and the violator injures a third party as a result of the chase, the officer's pursuit is not the proximate cause of those injuries unless the cireumstances indicate extreme or outrageous conduct by the officer. To put it another way, the possibil”
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.