State v. McBride’s Empirical Analysis
1997
Citation profile
19 state decisions
How this case has been cited
Cited by 20 later decisions — most recently September 2025
19 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 State v. Sanwick · State v. Carter · Robertson v. Sixpence Inns of America, Inc. · United States v. Vaknin · 8 Utah 2d 73 - Allred v. Hinkley
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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"Pecuniary damages" means all special damages, but not general damages, [2] which a person could recover against the defendant in a civil action arising out of the facts or events constituting the defendant's criminal activities and includes the money equivalent of property taken, destroyed, broken, or otherwise harmed, and losses including earnings and medical expenses.”
2 later decisions quote this exact passage“'would not have occurred but for the conduct underlying the [defendant's] conviction'”
2 later decisions quote this exact passage““Utah Code Ann. § 76-3-201(l)(d) (Supp.1996) defines ‘restitution’ as the ‘full, partial, or nominal payment for pecuniary damages to a victim.’ ... ‘Pecuniary damages’ are defined, in relevant part, as ‘all special damages, but not general damages, which a person could recover against the defendant in a civil action arising out of the facts or events constituting the defendant’s criminal activities and includes the money equivalent of property taken, destroyed, broken, or otherwise harmed.’ [[Image here]] “... [McBride] argues that the intervening negligence of the police supersedes his liability under a civil conversion theory of recovery. Utah law provides that ‘ “a more recent negligent act may break the chain of causation and relieve the liability of a prior negligent actor under the proper circumstances.” ’ Steffensen v. Smith’s Management Corp., 820 P.2d 482, 488 (Utah Ct.App.1991) (quoting Godesky v. Provo City Corp., 690 P.2d 541, 544 (Utah 1984)), aff'd, 862 P.2d 1342 (Utah 1993). ‘However, if the subsequent negligent act is foreseeable to the prior actor, both acts are concurring causes and the prior actor is not absolved of liability. The issue is whether the subsequent intervening conduct, either criminal or negligent, was reasonably foreseeable.’ Id. (citation omitted). “‘A superseding cause, sufficient to become the proximate cause of the final result and relieve defendant of liability for his original negligence, arises only when an intervening force was unfor”
1 later decision 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.