84 Wash. 2d 866 - Geise v. Lee’s Empirical Analysis
1975
Citation profile
36 state decisions
How this case has been cited
Cited by 36 later decisions — most recently April 2021 · most notably Degel v. Majestic Mobile Manor, Inc. (1996), 88 Wash. 2d 595 - Cherberg v. Peoples National Bank (1977)
36 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 Reardon v. Shimelman · Woods v. Naumkeag Steam Cotton Co. · 79 Wash. 2d 443 - McCutcheon v. United Homes Corp. · Langley Park Apartments, SEC. H., Inc. v. Lund · Fuller v. HOUSING AUTHORITY OF PROV.
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 36 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The duty of the landlord being to exercise reasonable care to prevent the occurrence of defective or dangerous conditions in the common approaches, the fact that a particular danger arose from the fall of snow or the freezing of ice can afford no ground of distinction. Indeed, the causes which are at work to produce it are no more natural causes than are those which, more slowly, bring about the decay of wood or the rusting of iron. To set apart this particular source of danger is to create a distinction without a sound difference.”
7 later decisions quote this exact passage“"We believe that today a landlord, armed with an ample supply of salt, sand, scrapers, shovels and even perhaps a snow blower, can acquit himself quite admirably as he takes to the common passageways to do battle with the fallen snow, the sun-melted snow now turned to ice, or the frozen rain. We fail to see the rationale for a rule which grants a seasonal exemption from liability to a landlord because he has failed to take adequate precautions against the hazards that can arise from the presence of unshoveled snow or unsanded or salt-free ice found in the areas of his responsibility but yet hold him liable on a year-round basis for other types of defects attributable to the workings of mother nature in the very same portions of his property.... To draw such a distinction ... `create[s] in the law another of those strange anomalies which, once created, live on to haunt successive legal generations.'" Id. (quoting Fuller v. Housing Auth., 108 R.I. 770, 773-74 , 279 A.2d 438 (1971) (quoting Langhorne Road Apartments, Inc. v. Bisson, 207 Va. 474, 477 , 150 S.E.2d 540 (1966))). Thus, a landowner must exercise reasonable care in keeping all common areas reasonably safe from hazards likely to cause injury, including snow and ice. Id. at 871, 529 P.2d 1054 .”
2 later decisions quote this exact passage“approximately 12 to 14 inches of snow fell and accumulated in the driveways. During the following week, melting and freezing conditions combined with passing cars, caused ridges of ice, 4 to 6 inches in height, to form throughout the common areas creating a hazardous condition for any tenant who ventured into these expanses.”
2 later decisions 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.