Leavitt v. Bickerton’s Empirical Analysis
1994
Citation profile
2 district · 6 state decisions
How this case has been cited
Cited by 8 later decisions — most recently December 2025
2 district · 6 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 Correllas v. Viveiros · Frazier v. Bailey · CRIBERG v. Raymond · 245 Cal. App. 2d 80 - Thornton v. Rhoden · Asay v. Hallmark Cards, Inc.
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Finally, it is of little significance that the statements made to Mrs. Leavitt's former employers were made by a private investigator and not by an attorney. The privilege conferred upon attorneys relates to their function as an advocate on behalf of their client, as is evidenced by the requirement that statements be made in the context of pending or ongoing litigation. Thus, insofar as [the investigator] was engaged in a function which would be protected had it been undertaken by an attorney, he is entitled to absolute immunity while acting as an agent of an attorney. [ Ibid. (citation omitted).]”
1 later decision quote this exact passage · from the majoritye.g. Hawkins v. Harris“need only be made in the course of judicial proceedings and be, in some way, related to those proceedings.”
1 later decision quote this exact passage · from the majoritye.g. Hawkins v. Harris“could have used a more tactful method of inquiry or otherwise saved Mrs. Leavitt humiliation and grief,”
1 later decision quote this exact passage · from the majoritye.g. Hawkins v. Harris
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.