Haynes v. Hamilton County’s Empirical Analysis
1994
Citation profile
9 federal appellate · 43 state decisions
How this case has been cited
Cited by 60 later decisions — most recently August 2023 · most notably McCarley v. West Quality Food Service (1998), McClung v. Delta Square Ltd. Partnership (1996)
9 federal appellate · 43 state decisions — followed in 10 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 Byrd v. Hall · Travis v. City of Mesquite · Bradshaw v. Daniel · Tetro v. Town of Stratford · Tice v. Cramer
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 60 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) the tortfeasor’s conduct must have been a “substantial factor” in bringing about the harm being complained of; and (2) there is no rule or policy that should relieve the wrongdoer from liability because of the manner in which the negligence has resulted in the harm; and (3) the harm giving rise to the action could have reasonably been foreseen or anticipated by a person of ordinary intelligence and prudence.”
8 later decisions quote this exact passage · from the dissent“With respect to superseding intervening causes that might break the chain of proximate causation, the rule is established that it is not necessary that tort-feasors or concurrent forces act in concert, or that there be a joint operation or a union of act or intent, in order for the negligence of each to be regarded as the proximate cause of the injuries, thereby rendering all tortfeasors hable. See Cartwright v. Graves, 182 Tenn. 114 , 184 S.W.2d 373, 381 (1944); Whitehurst v. Howell, 20 Tenn.App. 314 , 98 S.W.2d 1071, 1081 (1936); Morris v. Bolling, 31 Tenn.App. 577 , 218 S.W.2d 754, 758 (1949). There is no requirement that a cause, to be regarded as the proximate cause of an injury, be the sole cause, the last act, or the one nearest to the injury, provided it is a substantial factor in producing the end result. Lancaster, 390 S.W.2d at 221; Kroger Co., 387 S.W.2d at 626; Roberts [v. Yount, 692 S.W.2d 863 ] at 871. An intervening act, which is a normal response created by negligence, is not a superseding, intervening cause so as to relieve the original wrongdoer of liability, provided the intervening act could have reasonably been foreseen and the conduct was a substantial factor in bringing about the harm. Solomon v. Hall, 767 S.W.2d 158, 161 (Tenn.App.1988). “An intervening act will not exculpate the original wrongdoer unless it appears that the negligent intervening act could not have been reasonably anticipated.” Evridge v. American Honda Motor Co., 685 S.W.2d 632, 635 ”
1 later decision quote this exact passage · from the dissent“Notwithstanding the requirement of this section that drivers of authorized emergency vehicles exercise due regard for the safety of all persons, no municipality or county nor the state or any of its political subdivisions, nor their officers or employees, shall be liable for any injury proximately or indirectly caused to an actual or suspected violator of a law or ordinance who is fleeing pursuit by law enforcement personnel. The fact that law enforcement personnel pursue an actual or suspected violator of a law or ordinance who flees from pursuit shall not render the law enforcement personnel, or the employers of the law enforcement personnel, liable for injuries to a third party proximately caused by the fleeing party unless the conduct of the law enforcement personnel was negligent and that negligence was a proximate cause of the injuries to the third party.”
1 later decision quote this exact passage · from the dissent
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.