parental immunity (California) · Go Syfert
← California issues

parental immunity in California

11 California opinions name it 3 courts 1971–2025 1 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (12)

CaseFollowedCited
Gonzalez v. Santa Clara County Department of Social Servicesgreen
calctapp · 2014 · cited in 2 California opinions naming this issue, 2014–2025
2 sentences

2025Code, § 50, disapproved on other grounds in Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 853, fn. 19 .) Gonzalez held that because “the parental privilege to impose reasonable physical discipline upon a child must be incorporated into CANRA[],” the conduct of parents is “not reportable child abuse if it constituted the reasonable imposition of discipline.” (Gonzalez, supra, 223 Cal.App.4th at p. 90 .) The court noted that two definitions of child abuse in CANRA were “borrowed almost verbatim from the statutes defining two forms of criminal child abuse.” (Id. at p. 85, italics omitt

2014Code, § 300, subd. (a).)” (Gonzalez, supra, 223 Cal.App.4th at p. 86, fn. 11 .) 11 that CANRA “was aimed at criminal conduct” and that a disciplinary privilege had long been applied in criminal cases.4 (Id. at p. 88–89.) The court noted that the Legislature made CANRA a part of the Penal Code rather than the Welfare and Institutions Code or other codes.

12
Aguilar v. Atlantic Richfield Co.green
cal · 2001 · cited in 1 California opinions naming this issue, 2025–2025
1 sentence

2025Code, § 50, disapproved on other grounds in Aguilar v. Atlantic Richfield Co. (2001) 25 Cal.4th 826, 853, fn. 19 .) Gonzalez held that because “the parental privilege to impose reasonable physical discipline upon a child must be incorporated into CANRA[],” the conduct of parents is “not reportable child abuse if it constituted the reasonable imposition of discipline.” (Gonzalez, supra, 223 Cal.App.4th at p. 90 .) The court noted that two definitions of child abuse in CANRA were “borrowed almost verbatim from the statutes defining two forms of criminal child abuse.” (Id. at p. 85, italics omitt

11
Los Angeles County Department of Children & Family Services v. Kimberly G.green
calctapp · 2012 · cited in 1 California opinions naming this issue, 2014–2014
2 sentences

2014(See In re K.P., supra, 203 Cal.App.4th at p. 622; In re Andrea R., supra, 75 Cal.App.4th at p. 1109 .) After his child was removed from his mother’s custody, R.H. ceased almost all contact with the child.

2014(See In re K.P., supra, 203 Cal.App.4th at p. 622; In re Andrea R., supra, 75 Cal.App.4th at p. 1109 .) After his child was removed from his mother’s custody, R.H. ceased almost all contact with the child.

11
Volkland v. Volklandgreen
calctapp · 1977 · cited in 1 California opinions naming this issue, 1995–1995
2 sentences

1995(See In re Volkland (1977) 74 Cal.App.3d 674, 679-680 [ 141 Cal.Rptr. 625 ], hg. den. [mother’s leaving child with grandmother for nearly seven years supported clear showing that award to parent would be detrimental and award to nonparent was required to serve child’s best interest]; Chaffin v. Frye (1975) 45 Cal.App.3d 39, 46 [ 119 Cal.Rptr. 22 ] [girls’ continuous residence for “almost their entire lives” with grandparents was among “potent factors” supporting award of custody to grandparents]; cf. Guardianship of Barassi (1968) 265 Cal.App.2d 282, 288-290 [ 71 Cal.Rptr. 249 ] [discussing do

1995(See In re Volkland (1977) 74 Cal.App.3d 674, 679-680 [ 141 Cal.Rptr. 625 ], hg. den. [mother’s leaving child with grandmother for nearly seven years supported clear showing that award to parent would be detrimental and award to nonparent was required to serve child’s best interest]; Chaffin v. Frye (1975) 45 Cal.App.3d 39, 46 [ 119 Cal.Rptr. 22 ] [girls’ continuous residence for “almost their entire lives” with grandparents was among “potent factors” supporting award of custody to grandparents]; cf. Guardianship of Barassi (1968) 265 Cal.App.2d 282, 288-290 [ 71 Cal.Rptr. 249 ] [discussing do

11
Chaffin v. Fryegreen
calctapp · 1975 · cited in 1 California opinions naming this issue, 1995–1995
2 sentences

1995(See In re Volkland (1977) 74 Cal.App.3d 674, 679-680 [ 141 Cal.Rptr. 625 ], hg. den. [mother’s leaving child with grandmother for nearly seven years supported clear showing that award to parent would be detrimental and award to nonparent was required to serve child’s best interest]; Chaffin v. Frye (1975) 45 Cal.App.3d 39, 46 [ 119 Cal.Rptr. 22 ] [girls’ continuous residence for “almost their entire lives” with grandparents was among “potent factors” supporting award of custody to grandparents]; cf. Guardianship of Barassi (1968) 265 Cal.App.2d 282, 288-290 [ 71 Cal.Rptr. 249 ] [discussing do

1995(See In re Volkland (1977) 74 Cal.App.3d 674, 679-680 [ 141 Cal.Rptr. 625 ], hg. den. [mother’s leaving child with grandmother for nearly seven years supported clear showing that award to parent would be detrimental and award to nonparent was required to serve child’s best interest]; Chaffin v. Frye (1975) 45 Cal.App.3d 39, 46 [ 119 Cal.Rptr. 22 ] [girls’ continuous residence for “almost their entire lives” with grandparents was among “potent factors” supporting award of custody to grandparents]; cf. Guardianship of Barassi (1968) 265 Cal.App.2d 282, 288-290 [ 71 Cal.Rptr. 249 ] [discussing do

11
Guardianship of Barassigreen
calctapp · 1968 · cited in 1 California opinions naming this issue, 1995–1995
2 sentences

1995(See In re Volkland (1977) 74 Cal.App.3d 674, 679-680 [ 141 Cal.Rptr. 625 ], hg. den. [mother’s leaving child with grandmother for nearly seven years supported clear showing that award to parent would be detrimental and award to nonparent was required to serve child’s best interest]; Chaffin v. Frye (1975) 45 Cal.App.3d 39, 46 [ 119 Cal.Rptr. 22 ] [girls’ continuous residence for “almost their entire lives” with grandparents was among “potent factors” supporting award of custody to grandparents]; cf. Guardianship of Barassi (1968) 265 Cal.App.2d 282, 288-290 [ 71 Cal.Rptr. 249 ] [discussing do

1995(See In re Volkland (1977) 74 Cal.App.3d 674, 679-680 [ 141 Cal.Rptr. 625 ], hg. den. [mother’s leaving child with grandmother for nearly seven years supported clear showing that award to parent would be detrimental and award to nonparent was required to serve child’s best interest]; Chaffin v. Frye (1975) 45 Cal.App.3d 39, 46 [ 119 Cal.Rptr. 22 ] [girls’ continuous residence for “almost their entire lives” with grandparents was among “potent factors” supporting award of custody to grandparents]; cf. Guardianship of Barassi (1968) 265 Cal.App.2d 282, 288-290 [ 71 Cal.Rptr. 249 ] [discussing do

11
Baxter v. Superior Courtgreen
cal · 1977 · cited in 1 California opinions naming this issue, 1989–1989
2 sentences

1989The intangible character of the loss, which can never really be compensated by money damages; the difficulty of measuring damages; the dangers of double recovery or multiple claims and of extensive liability — all these considerations apply similarly to both cases." ( Baxter v. Superior Court (1977) 19 Cal.3d 461, 464 [ 138 Cal. Rptr. 315 , 563 P.2d 871 ].) [9] "[A] distinction between distress caused by personal observation of the injury and by hearing of the tragedy from another is justified because compensation should be limited to abnormal life experiences which cause emotional distress.

1989The intangible character of the loss, which can never really be compensated by money damages; the difficulty of measuring damages; the dangers of double recovery or multiple claims and of extensive liability — all these considerations apply similarly to both cases." ( Baxter v. Superior Court (1977) 19 Cal.3d 461, 464 [ 138 Cal. Rptr. 315 , 563 P.2d 871 ].) [9] "[A] distinction between distress caused by personal observation of the injury and by hearing of the tragedy from another is justified because compensation should be limited to abnormal life experiences which cause emotional distress.

11
Gibson v. Gibsongreen
cal · 1971 · cited in 1 California opinions naming this issue, 1973–1973
2 sentences

1973Most recently in Gibson v. Gibson (1971) 3 Cal.3d 914, 919-920 [ 92 Cal.Rptr. 288 , 479 P.2d 648 ] we invoked the teachings of Emery and Klein in rejecting a parallel contention that the broad parental immunity doctrine, which barred all negligence actions by children against their parents, could be sustained on a “collusion prevention” rationale.

1973Most recently in Gibson v. Gibson (1971) 3 Cal.3d 914, 919-920 [ 92 Cal.Rptr. 288 , 479 P.2d 648 ] we invoked the teachings of Emery and Klein in rejecting a parallel contention that the broad parental immunity doctrine, which barred all negligence actions by children against their parents, could be sustained on a “collusion prevention” rationale.

11
Dillon v. Legggreen
cal · 1968 · cited in 1 California opinions naming this issue, 1973–1973
2 sentences

1973The Gibson court, while conceding that “some danger of collusion cannot be denied,” observed that “the peril is no greater when a minor sues his parent than in actions between husbands and wives, brothers and sisters or adult children and parents, all of which are permitted in *875 California.” (See also Dillon v. Legg (1968) 68 Cal.2d 728, 735-739 [ 69 Cal.Rptr. 72 , 441 P.2d 912 , 29 A.L.R.3d 1316 ].) These three cases, Emery, Klein and Gibson , dealing with the entire range of intrafamilial immunities, establish that it is unreasonable to eliminate causes of action of an entire class of per

1973The Gibson court, while conceding that “some danger of collusion cannot be denied,” observed that “the peril is no greater when a minor sues his parent than in actions between husbands and wives, brothers and sisters or adult children and parents, all of which are permitted in *875 California.” (See also Dillon v. Legg (1968) 68 Cal.2d 728, 735-739 [ 69 Cal.Rptr. 72 , 441 P.2d 912 , 29 A.L.R.3d 1316 ].) These three cases, Emery, Klein and Gibson , dealing with the entire range of intrafamilial immunities, establish that it is unreasonable to eliminate causes of action of an entire class of per

11
Dunlap v. Dunlapgreen
· 1930 · cited in 1 California opinions naming this issue, 1971–1971
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Although the oft-compared rule of interspousal immunity reached back to the early common law, English law books record no case involving a personal tort suit between parent and child. ( Dunlap v. Dunlap (1930) 84 N.H. 352, 356 [ 150 A. 905 , 71 A.L.R. 1055 ]; Prosser, Torts (3d ed. 1964) § 116, p. 886; Annot. (1951) 19 A.L.R.2d 423 , 425; see McCurdy, Torts Between Persons in Domestic Relation (1930) 43 Harv.L.Rev. 1030, 1059-1060.) Since children have long been allowed to sue their parents in matters involving property, however, some scholars have concluded that "there is no good reason to th

11
Myers v. Tranquility Irrigation Districtgreen
calctapp · 1938 · cited in 1 California opinions naming this issue, 1971–1971
11
Goller v. Whitegreen
wis · 1963 · cited in 1 California opinions naming this issue, 1971–1971
2 sentences

1971(See Goller v. White (1963) 20 Wis.2d 402, 410 [ 122 N.W.2d 193 ].) [8] See also Report of the American Bar Association Special Committee on Automobile Accident Reparations at pages 85-86, which, while recognizing that there is some possibility of fraud, concludes that this danger is outweighed by the desirability of compensating injured minors for the automobile torts of their parents. [9] The Legislature has acted to bar suits in one situation where the danger of fraud and collusion was thought to be great — an action by an automobile guest against his host for simple negligence (Veh.

1971(See Goller v. White (1963) 20 Wis.2d 402, 410 [ 122 N.W.2d 193 ].) [8] See also Report of the American Bar Association Special Committee on Automobile Accident Reparations at pages 85-86, which, while recognizing that there is some possibility of fraud, concludes that this danger is outweighed by the desirability of compensating injured minors for the automobile torts of their parents. [9] The Legislature has acted to bar suits in one situation where the danger of fraud and collusion was thought to be great — an action by an automobile guest against his host for simple negligence (Veh.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (20)

CaseCitedYears
Los Angeles County Department of Children & Family Services v. Daniel R. green
calctapp · 1999
1 sentence

2014(See In re K.P., supra, 203 Cal.App.4th at p. 622; In re Andrea R., supra, 75 Cal.App.4th at p. 1109 .) After his child was removed from his mother’s custody, R.H. ceased almost all contact with the child.

12014–2014
In Re Cliffton B. green
calctapp · 2000
1 sentence

2013(In re Cliffton B. (2000) 81 Cal.App.4th 415, 424-425 ; Autumn H., supra, 27 Cal.App.4th at p. 576 .) Under this standard, an appellate court must affirm the juvenile court’s order if there is evidence that is reasonable, credible, and of solid value to support the order (In re Christina A. (1989) 213 Cal.App.3d 1073, 1080 ), and the evidence must be considered “in the light most favorable to the prevailing party, giving the prevailing party the benefit 16 of every reasonable inference and resolving all conflicts in support of the order. [Citations.]” (Autumn H., at p. 576.) There is ample sup

12013–2013
In Re Autumn H. green
calctapp · 1994
1 sentence

2013(In re Cliffton B. (2000) 81 Cal.App.4th 415, 424-425 ; Autumn H., supra, 27 Cal.App.4th at p. 576 .) Under this standard, an appellate court must affirm the juvenile court’s order if there is evidence that is reasonable, credible, and of solid value to support the order (In re Christina A. (1989) 213 Cal.App.3d 1073, 1080 ), and the evidence must be considered “in the light most favorable to the prevailing party, giving the prevailing party the benefit 16 of every reasonable inference and resolving all conflicts in support of the order. [Citations.]” (Autumn H., at p. 576.) There is ample sup

12013–2013
In Re Christina A. green
calctapp · 1989
1 sentence

2013(In re Cliffton B. (2000) 81 Cal.App.4th 415, 424-425 ; Autumn H., supra, 27 Cal.App.4th at p. 576 .) Under this standard, an appellate court must affirm the juvenile court’s order if there is evidence that is reasonable, credible, and of solid value to support the order (In re Christina A. (1989) 213 Cal.App.3d 1073, 1080 ), and the evidence must be considered “in the light most favorable to the prevailing party, giving the prevailing party the benefit 16 of every reasonable inference and resolving all conflicts in support of the order. [Citations.]” (Autumn H., at p. 576.) There is ample sup

12013–2013
In Re IW green
calctapp · 2009
2 sentences

2012This distinction was addressed in In re I.W. (2009) 180 Cal.App.4th 1517 [ 103 Cal.Rptr.3d 538 ], a juvenile dependency case, where the trial court held that the mother produced insufficient evidence to meet the requirements of the parental exception to termination of her parental rights.

2012This distinction was addressed in In re I.W. (2009) 180 Cal.App.4th 1517 [ 103 Cal.Rptr.3d 538 ], a juvenile dependency case, where the trial court held that the mother produced insufficient evidence to meet the requirements of the parental exception to termination of her parental rights.

12012–2012
Broadbent v. Broadbent green
ariz · 1995
2 sentences

2008The following three cases, relied on by Padilla, are distinguishable and are of no aid to her. *751 The case of Broadbent v. Broadbent (1995) 184 Ariz. 74 [ 907 P.2d 43 ] is inapplicable because it was a suit by a child against a parent and involved the parental immunity doctrine.

2008The following three cases, relied on by Padilla, are distinguishable and are of no aid to her. *751 The case of Broadbent v. Broadbent (1995) 184 Ariz. 74 [ 907 P.2d 43 ] is inapplicable because it was a suit by a child against a parent and involved the parental immunity doctrine.

12008–2008
Adler v. Copeland green
fladistctapp · 1958
1 sentence

2008In Adler v. Copeland (Fla.Dist.Ct.App. 1958) 105 So.2d 594 (Adler), the District Court of Appeal of Florida reversed a judgment of involuntary nonsuit entered after the trial court indicated an intention to direct a verdict in favor of the defendant.

12008–2008
Dix v. Superior Court green
cal · 1991
1 sentence

2000(Dix v. Superior Court (1991) 53 Cal.3d 442 , 460 ; Nipper v. California Auto.

12000–2000
Martinez v. Southern Pacific Co. green
cal · 1955
2 sentences

1971No sooner had American courts, including our own, embraced the parental immunity doctrine than they began to fashion a number of qualifications and exceptions to it. 4 In Martinez v. Southern Pacific Co., supra, 45 Cal.2d 244 , we allowed an emancipated minor to sue her parent for simple negligence; in Emery v. Emery (1955) 45 Cal.2d 421 [ 289 P.2d 218 ], we held that wilful or malicious torts were not within the scope of the immunity.

1971No sooner had American courts, including our own, embraced the parental immunity doctrine than they began to fashion a number of qualifications and exceptions to it. [4] In Martinez v. Southern Pacific Co., supra, 45 Cal.2d 244 , we allowed an emancipated minor to sue her parent for simple negligence; in Emery v. Emery (1955) 45 Cal.2d 421 [ 289 P.2d 218 ], we held that wilful or malicious torts were not within the scope of the immunity.

11971–1971
O'Connor v. Benson Coal Co. green
mass · 1938
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Chase v. New Haven Waste Material Corporation green
conn · 1930
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Johnson v. Alabama & Georgia Iron Co. green
gactapp · 1911
1 sentence

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Davis v. Smith green
ca3 · 1958
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine's idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent ( Davis v. Smith (3d Cir.1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity ( Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.

11971–1971
Brennecke Ex Rel. Brennecke v. Kilpatrick green
mo · 1960
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine's idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent ( Davis v. Smith (3d Cir.1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity ( Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.

11971–1971
Borst v. Borst green
wash · 1952
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Emery v. Emery green
cal · 1955
2 sentences

1971No sooner had American courts, including our own, embraced the parental immunity doctrine than they began to fashion a number of qualifications and exceptions to it. 4 In Martinez v. Southern Pacific Co., supra, 45 Cal.2d 244 , we allowed an emancipated minor to sue her parent for simple negligence; in Emery v. Emery (1955) 45 Cal.2d 421 [ 289 P.2d 218 ], we held that wilful or malicious torts were not within the scope of the immunity.

1971No sooner had American courts, including our own, embraced the parental immunity doctrine than they began to fashion a number of qualifications and exceptions to it. 4 In Martinez v. Southern Pacific Co., supra, 45 Cal.2d 244 , we allowed an emancipated minor to sue her parent for simple negligence; in Emery v. Emery (1955) 45 Cal.2d 421 [ 289 P.2d 218 ], we held that wilful or malicious torts were not within the scope of the immunity.

11971–1971
Dean v. Smith green
nh · 1965
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Lusk v. Lusk green
wva · 1932
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Mi-Lady Cleaners v. McDaniel green
ala · 1938
2 sentences

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

1971Courts in other states compounded the doctrine’s idiosyncrasies in decisions permitting tort actions by minors against the estate of a deceased parent (Davis v. Smith (3d Cir. 1958) 253 F.2d 286 ; Dean v. Smith (1965) 106 N.H. 314 [ 211 A.2d 410 ]; Brennecke v. Kilpatrick (Mo. 1960) 336 S.W.2d 68 ); against the parent in his business capacity (Signs v. Signs (1952) 156 Ohio St. 566 [ 103 N.E.2d 743 ]; Borst v. Borst (1952) 41 Wn.2d 642 [ 251 P.2d 149 ]; Lusk v. Lusk (1932) 113 W.Va. 17 [ 166 S.E. 538 ]; Dunlap v. Dunlap, supra, 84 N.H. 352 ); and against the parent’s employer under respondeat

11971–1971
Stapleton v. Stapleton green
gactapp · 1952
11971–1971

Statutes the citing opinions construe

CA § Cal. Civil Code § 1714 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 212 (1986–2026) CT 83 (1972–2006) PA 60 (1957–2026) AL 52 (1984–2026) MI 47 (1966–2025) UT 42 (1982–2024) MO 32 (1960–2025) IL 31 (1966–2004) FL 26 (1980–2025) VA 26 (1971–2026) MD 25 (1976–2022) IN 23 (1974–2026) NJ 20 (1960–2009) WA 20 (1979–2019) DC 20 (1985–2022) MA 18 (1975–2025) CO 17 (1974–2011) OH 16 (1981–2013) WV 14 (1968–2020) AR 14 (1980–2021) KY 14 (1970–2024) AZ 13 (1970–2021) NC 13 (1972–2024) MN 12 (1966–2026) OR 11 (1976–2016) CA 11 (1971–2025) IA 11 (1968–2022) NM 10 (1996–2025) WI 10 (1963–2005) NY 9 (1974–2013) MS 8 (1970–2016) SC 7 (1980–2001) KS 7 (1966–2025) ME 6 (1966–2000) TN 6 (1928–2005) DE 6 (1976–1997) GA 5 (1972–1993) ID 5 (1980–2011) OK 4 (1984–2023) WY 3 (1992–2023) MT 3 (1983–2025) NV 3 (1996–2013) SD 3 (2007–2025) LA 3 (1995–2016) ND 2 (2012–2012) HI 2 (2007–2026) NH 2 (1984–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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