85 Wash. 2d 52 - Grimsby v. Samson’s Empirical Analysis
1975
Citation profile
26 federal appellate · 2 district · 157 state decisions
How this case has been cited
Cited by 255 later decisions — most recently October 2021 · most notably 48 Cal. 3d 644 - Thing v. La Chusa (1989), Twyman v. Twyman (1993)
26 federal appellate · 2 district · 157 state decisions — followed in 14 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 Dillon v. Legg · Niederman v. Brodsky · Rodrigues v. State · Tobin v. Grossman · Archibald v. Braverman
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 255 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“so outrageous in character, and so extreme in degree, as to go beyond all possible bounds of decency, and to be regarded as atrocious, and utterly intolerable in a civilized community.”
49 later decisions quote this exact passage“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.”
6 later decisions quote this exact passage“(a) the position occupied by the defendant; (b) whether plaintiff was peculiarly susceptible to emotional distress, and if defendant knew this fact; (c) whether defendant's conduct may have been privileged under the circumstances; (d) the degree of emotional distress caused by a party must be severe as opposed to constituting mere annoyance, inconvenience or the embarrassment which normally occur in a confrontation of the parties; and, (e) the actor must be aware that there is a high probability that his conduct will cause severe emotional distress and he must proceed in a conscious disregard of it.”
5 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.