Samedan Oil Corp. v. Neeld’s Empirical Analysis
1978
Citation profile
2 district · 55 state decisions
How this case has been cited
Cited by 61 later decisions — most recently November 2003 · most notably Gionfriddo v. Avis Rent A Car System, Inc. (1984), Romero v. Mervyn's (1989)
2 district · 55 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 Lake Shore Ry Co v. Prentice · Loucks v. Albuquerque National Bank · Barnes v. Smith · Stewart v. Potter · Miera v. George
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ * * * Whether or not an employee is acting ‘within the scope or course of his employment’ is not the standard under which punitive damages may be assessed against his employer. This point of law was clearly settled in Sanchez v. Securities Acceptance Corp., supra [ 57 N.M. 512 , 260 P.2d 703 ] where we said: “ ‘The law of New Mexico, as set forth in [Stewart v. Potter, supra, 44 N.M. 460 , 104 P.2d 736 , and Miera v. George, 55 N.M. 535 , 237 P.2d 102 (1957)] establishes the rule that a principal is liable for compensatory damages arising out of the tortious act of an employee acting within the scope of his authority * * *; but the principal is not liable for punitive damages for the same act, unless it is proved, over and above the fact that the agent was acting within the scope of his authority, that the principal participated in, authorized, or ratified the actual tortious conduct of the agent. (Emphasis added.)’ “Id. 57 N.M. at 516-517 , 260 P.2d at 706-707 .” (Bracketed material in original.)”
1 later decision quote this exact passagee.g. Campen v. Stone“It is the established law of New Mexico that punitive or exemplary damages may be awarded “only when the conduct of the wrongdoer may be said to be maliciously intentional, fraudulent, oppressive, or committed recklessly or with a wanton disregard of the plaintiff’s rights.” Loucks v. Albuquerque National Bank, 76 N.M. 735, 747 , 418 P.2d 191, 199 (1966).”
1 later decision quote this exact passage“is liable for punitive or exemplary damages only in cases where the principal or master has in some way authorized, participated in or ratified the acts of the agent or servant, which acts were wanton, oppressive, malicious, fraudulent or criminal in nature.”
1 later decision quote this exact passagee.g. Campbell v. Bartlett
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.