Deem v. Charles E. Smith Management, Inc.’s Empirical Analysis
799 F.2d 944 · 1986
Citation profile
2 federal appellate · 12 state decisions
How this case has been cited
Cited by 19 later decisions — most recently September 2005
2 federal appellate · 12 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 United Housing Foundation, Inc. v. Forman · Gulf Reston, Inc. v. Rogers · Wicks v. City of Charlottesville · Revell v. Deegan
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 19 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he Virginia Residential Landlord and Tenant Act does not define a ‘safe condition’ as used in § 55-248.13(a)(3) or ‘safety’ as used in § 55-248.13(a)(l). We believe, however, that those terms refer to the protection of the tenant from injuries caused by failures of the building — collapsing stairs, faulty walls, dangerous windows. This interpretation is consistent with the common law recognition of a landlord’s ‘duty to use ordinary care to keep [common areas] in a reasonably safe condition.’ This interpretation still recognizes that, there exist legal duties in Virginia to promote tenant safety apart from the duty to protect against third-party acts.”
2 later decisions quote this exact passage · from the majority“‘keep all common areas shared by two or more dwelling units of the premises in a clean and safe condition!,]' ” but also for a landlord to”
1 later decision quote this exact passage · from the majority“Where there is no legal duty to exercise care, there can be no actionable negligence.”
1 later decision quote this exact passage · from the majority
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.