Schaffer v. Bess’s Empirical Analysis
1991
Citation profile
2 federal appellate · 28 state decisions
How this case has been cited
Cited by 37 later decisions — most recently November 2015 · most notably Boggs Ex Rel. Boggs v. Lay (2005), M.C. v. Yeargin (2000)
2 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 Murphy v. Carron · DeWitt v. American Family Mutual Insurance Co. · Krause v. US Truck Co., Inc. · Floyd v. St. Louis Public Service Company · Eichelberger v. Barnes Hospital
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 37 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"An intervening cause is a new and independent force which so interrupts the chain of events as to become the responsible, direct, proximate and immediate cause of the injury, rendering any prior negligence too remote to operate as the proximate cause." (citation omitted). It may not consist of an act of concurring or contributing negligence. Moreover, it may not be one which is itself a foreseeable and natural result of the original negligence.”
3 later decisions quote this exact passage““The practical test of proximate cause is whether the negligence is an efficient cause which sets in motion the chain of circumstances leading to the plaintiffs injuries or damages [citation omitted]. The test is not whether a reasonably prudent person would have foreseen the particular injury [citation omitted]. Instead, the test is whether, after the occurrences, the injury appears to be the reasonable and probable consequence of the act or omission of the defendant. The defendant’s negligence need not be the sole cause of the injury. It is sufficient that it be one of the efficient causes thereof, without which the injury would not have occurred. A party is liable if his negligence, combined with the negligence of others, results in injury to another.””
1 later decision quote this exact passage“When a person negligently makes a left-hand turn onto a busy highway and thereby causes a car to strike him, it is probable that multiple collisions will follow. It is particularly probable that other automobiles will collide with vehicles involved in the initial accident. [[Image here]] Clearly, [the] negligent act [of the driver who made a left-hand turn onto the busy highway] was not the sole cause of [the injury in the second accident]. Rather, it was one of the efficient causes thereof ... without which [the second injury] would not have occurred. Since a party is liable if his negligence, combined with the negligence of others, results in injury, [the first driver] ... is liable.”
1 later decision quote this exact passagee.g. Hargis v. Lankford
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.