85 Wash. 2d 883 - Jenkins v. State’s Empirical Analysis
1975
Citation profile
64 state decisions
How this case has been cited
Cited by 64 later decisions — most recently March 2009 · most notably 100 Wash. 2d 421 - Petersen v. State (1983), 90 Wis. 2d 823 - Stanhope v. Brown County (1979)
64 state decisions — followed in 13 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 Reed v. Reed · Royster Guano Co v. Commonwealth of Virginia · Rinaldi v. Yeager · Halliburton Oil Well Cementing Co. v. Reily · Gregg Dyeing Co. v. Query
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 64 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"All political subdivisions, municipal corporations, and quasi municipal corporations of the state, whether acting in a governmental or proprietary capacity, shall be liable for damages arising out of their tortious conduct, or the tortious conduct of their officers, agents or employees to the same extent as if they were a private person or corporation: Provided, That the filing within the time allowed by law of any claim required shall be a condition precedent to the maintaining of any action. The laws specifying the content for such claims shall be liberally construed so that substantial compliance therewith will be deemed satisfactory.””
4 later decisions quote this exact passage“(1) the later act covers the entire subject matter of the earlier legislation, is complete in itself, and is evidently intended to supersede prior legislation on the subject; or (2) the two acts are so clearly inconsistent with, and repugnant to, each other that they cannot be reconciled and both given effect by a fair and reasonable construction.”
4 later decisions quote this exact passage““In practical terms, then, RCW 36.45.-030, in the context of other statutes relating to governmental tort liability, establishes two distinct levels of classification or discrimination. First, the provision treats counties differently than all other governmental entities, including the state, by providing for a significantly shorter period during which actions may be commenced against it. Second, the statute discriminates between victims of the tortious conduct of counties and victims of the tortious conduct of other governmental entities. In effect, victims of the tortious conduct of counties suffer the ‘burden’ of having to commence their actions within three months of the expiration of the ‘presentation period’, while victims of the tortious conduct of other governmental entities, including the state, enjoy the relative ‘privilege’ of commencing their actions within three years of the date of the occurrence. In other words, RCW 36.45.030 provides a glaring exception to the otherwise uniform scheme of governmental tort liability in the State of Washington. “No rational permissible reason has been offered, nor have we been able to discern one, which would justify making such a distinction between counties and other governmental entities or between victims of the tortious conduct of counties and victims of the tortious conduct of other governmental entities. The only reasons offered by respondent to justify the classifications made relate to the reasonableness of limitations ”
3 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.