increased risk doctrine (New Jersey) · Go Syfert
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increased risk doctrine in New Jersey

7 New Jersey opinions name it 2 courts 1957–2003 0 in the last five years

The cases below were cited by New Jersey 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 (4)

CaseFollowedCited
Evers v. Dollingergreen
nj · 1984 · cited in 3 New Jersey opinions naming this issue, 1989–1997
2 sentences

1990In this case, as in Scafidi v. Seiler, 119 N.J. 93 , 574 A. 2d 398 (1990), also decided today, we consider application of the doctrine of increased risk, see Evers v. Dollinger, 95 N.J. 399 , *122 471 A. 2d 405 (1984), in medical-malpractice litigation.

1990In this case, as in Scafidi v. Seiler, 119 N.J. 93 , 574 A. 2d 398 (1990), also decided today, we consider application of the doctrine of increased risk, see Evers v. Dollinger, 95 N.J. 399 , *122 471 A. 2d 405 (1984), in medical-malpractice litigation.

13
Idaho v. Wrightgreen
scotus · 1990 · cited in 1 New Jersey opinions naming this issue, 1996–1996
2 sentences

1996Our rules of evidence insist that only statements subject to cross-examination, or other statements where "circumstantial guarantees of trustworthiness" exist, should be admitted as evidence. 2 McCormick on Evidence § 253, at 130 (citation omitted) (4th ed. 1992); see also Idaho v. Wright, 497 U.S. 805, 820 , 110 S.Ct. 3139, 3149 , 111 L.Ed. 2d 638, 655 (1990) (explaining that "if the declarant's truthfulness is so clear from the surrounding circumstances that the test of cross-examination would be of marginal utility, then the hearsay rule does not bar admission.") C.A. contends that, because

1996Our rules of evidence insist that only statements subject to cross-examination, or other statements where "circumstantial guarantees of trustworthiness" exist, should be admitted as evidence. 2 McCormick on Evidence § 253, at 130 (citation omitted) (4th ed. 1992); see also Idaho v. Wright, 497 U.S. 805, 820 , 110 S.Ct. 3139, 3149 , 111 L.Ed. 2d 638, 655 (1990) (explaining that "if the declarant's truthfulness is so clear from the surrounding circumstances that the test of cross-examination would be of marginal utility, then the hearsay rule does not bar admission.") C.A. contends that, because

11
Geltman v. Reliable Linen & Supply Co.green
nj · 1942 · cited in 1 New Jersey opinions naming this issue, 1957–1957
1 sentence

1957Highway robbery is perhaps the most common fact situation to which this rule is applied, since, as one court pointed out, `its name indicates that it is a danger incident to, connected with, and "arising out of" the use of highways.' Note that in these cases the exposure to the risk on the highway is in itself enough to establish the causal connection; there need be no evidence of carrying the employer's money or of protecting his property." See also Geltman v. Reliable Linen & Supply Co., 128 N.J.L. 443, 449 ( E. & A. 1942); Bobertz v. Board of Education of Hillside Tp., 134 N.J.L. 444, 448 (

11
Bobertz v. Board of Education of Hillside Twp.green
nj · 1946 · cited in 1 New Jersey opinions naming this issue, 1957–1957
1 sentence

1957Highway robbery is perhaps the most common fact situation to which this rule is applied, since, as one court pointed out, `its name indicates that it is a danger incident to, connected with, and "arising out of" the use of highways.' Note that in these cases the exposure to the risk on the highway is in itself enough to establish the causal connection; there need be no evidence of carrying the employer's money or of protecting his property." See also Geltman v. Reliable Linen & Supply Co., 128 N.J.L. 443, 449 ( E. & A. 1942); Bobertz v. Board of Education of Hillside Tp., 134 N.J.L. 444, 448 (

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
Scafidi v. Seiler green
nj · 1990
2 sentences

2003My colleagues analogize this situation to the increased risk analysis adopted by the Court in the context of medical malpractice litigation in Scafidi v. Seiler, 119 N.J. 93 , 574 A. 2d 398 (1990).

2003My colleagues analogize this situation to the increased risk analysis adopted by the Court in the context of medical malpractice litigation in Scafidi v. Seiler, 119 N.J. 93 , 574 A. 2d 398 (1990).

21990–2003
Gardner v. Pawliw green
njsuperctappdiv · 1995
2 sentences

1997Consequently, Dr. Kalafer was unable to state “within a reasonable degree of medical probability” that either test would have produced positive results that could have led to the early delivery of the baby— Dr. Kalafer’s [testimony] constituted a bare conclusion, unsupported by any opinion as to the critical underlying fact of the fetus’s condition as of December 21, 1988. [ 285 N.J.Super. 113, 122 , 666 A.2d 592 (1995).] The majority disagrees, taking comfort in measuring Dr. Kalafer’s testimony against a lower standard of causation, the increased-risk standard.

1997Consequently, Dr. Kalafer was unable to state “within a reasonable degree of medical probability” that either test would have produced positive results that could have led to the early delivery of the baby— Dr. Kalafer’s [testimony] constituted a bare conclusion, unsupported by any opinion as to the critical underlying fact of the fetus’s condition as of December 21, 1988. [ 285 N.J.Super. 113, 122 , 666 A.2d 592 (1995).] The majority disagrees, taking comfort in measuring Dr. Kalafer’s testimony against a lower standard of causation, the increased-risk standard.

11997–1997
Gardner v. Pawliw green
nj · 1997
1 sentence

1997Ante at 390-391, 696 A. 2d at 616-617 .

11997–1997
Lanzet v. Greenberg green
nj · 1991
2 sentences

1991The majority's only explanation for ignoring that requirement is "[t]his case illustrates the complexities of presenting medical causation issues to a jury when there is a preexisting condition." Id. at 188 , 594 A. 2d at 1320 .

1991The majority's only explanation for ignoring that requirement is "[t]his case illustrates the complexities of presenting medical causation issues to a jury when there is a preexisting condition." Id. at 188 , 594 A. 2d at 1320 .

11991–1991
Bobertz v. Board of Education of Hillside Twp. green
nj · 1947
1 sentence

1957Highway robbery is perhaps the most common fact situation to which this rule is applied, since, as one court pointed out, `its name indicates that it is a danger incident to, connected with, and "arising out of" the use of highways.' Note that in these cases the exposure to the risk on the highway is in itself enough to establish the causal connection; there need be no evidence of carrying the employer's money or of protecting his property." See also Geltman v. Reliable Linen & Supply Co., 128 N.J.L. 443, 449 ( E. & A. 1942); Bobertz v. Board of Education of Hillside Tp., 134 N.J.L. 444, 448 (

11957–1957

Where else courts name it

AZ 10 (1990–2023) AR 9 (1993–2025) NJ 7 (1957–2003) NV 7 (2010–2019) OK 6 (1998–2008) NC 6 (1997–2009) AL 4 (2002–2025) MD 4 (2000–2014) IN 3 (1950–2017) NE 3 (1986–2016) NH 3 (2011–2024) SD 3 (2000–2000) NY 2 (1997–2002) LA 2 (1977–1982) IA 2 (2007–2018) CA 2 (1993–2024) TN 2 (1966–1979) KY 2 (1992–2025) MN 2 (2013–2017)

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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