causation requirement (Rhode Island) · Go Syfert
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causation requirement in Rhode Island

7 Rhode Island opinions name it 2 courts 1993–2008 0 in the last five years

The cases below were cited by Rhode Island 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 (5)

CaseFollowedCited
Contois v. Town of West Warwickgreen
ri · 2004 · cited in 2 Rhode Island opinions naming this issue, 2008–2008
2 sentences

2008See Contois v. Town of West Warwick, 865 A.2d 1019 , *451 1023 (R.I.2004) (discussing the causation requirement in negligence actions); Clift v. Vose Hardware, Inc., 848 A.2d 1130, 1132 (R.I.2004) (discussing the causation requirement in the products liability context); Salk v. Alpine Ski Shop, Inc., 115 R.I. 309, 314-15 , 342 A.2d 622, 626 (1975) (concluding that, even under strict liability, a plaintiff must show “a causal connection between the defect and the injury”).

2008Rather than prove proximate cause, “the plaintiff need only establish that ‘defendant’s negligence was a proximate cause of the lost chance to avoid the ultimate harm.’ ” Contois, 865 A.2d at 1023 (quoting Mead, 670 N.W.2d at 186 ).

12
Clift v. Vose Hardware, Inc.green
ri · 2004 · cited in 1 Rhode Island opinions naming this issue, 2008–2008
1 sentence

2008See Contois v. Town of West Warwick, 865 A.2d 1019 , *451 1023 (R.I.2004) (discussing the causation requirement in negligence actions); Clift v. Vose Hardware, Inc., 848 A.2d 1130, 1132 (R.I.2004) (discussing the causation requirement in the products liability context); Salk v. Alpine Ski Shop, Inc., 115 R.I. 309, 314-15 , 342 A.2d 622, 626 (1975) (concluding that, even under strict liability, a plaintiff must show “a causal connection between the defect and the injury”).

11
Salk v. Alpine Ski Shop, Inc.green
ri · 1975 · cited in 1 Rhode Island opinions naming this issue, 2008–2008
2 sentences

2008See Contois v. Town of West Warwick, 865 A.2d 1019 , *451 1023 (R.I.2004) (discussing the causation requirement in negligence actions); Clift v. Vose Hardware, Inc., 848 A.2d 1130, 1132 (R.I.2004) (discussing the causation requirement in the products liability context); Salk v. Alpine Ski Shop, Inc., 115 R.I. 309, 314-15 , 342 A.2d 622, 626 (1975) (concluding that, even under strict liability, a plaintiff must show “a causal connection between the defect and the injury”).

2008See Contois v. Town of West Warwick, 865 A.2d 1019 , *451 1023 (R.I.2004) (discussing the causation requirement in negligence actions); Clift v. Vose Hardware, Inc., 848 A.2d 1130, 1132 (R.I.2004) (discussing the causation requirement in the products liability context); Salk v. Alpine Ski Shop, Inc., 115 R.I. 309, 314-15 , 342 A.2d 622, 626 (1975) (concluding that, even under strict liability, a plaintiff must show “a causal connection between the defect and the injury”).

11
Glenn v. Aikengreen
mass · 1991 · cited in 1 Rhode Island opinions naming this issue, 2002–2002
2 sentences

2002In Glenn v. Aiken, 409 Mass. 699 , 569 N.E.2d 783, 788 (1991), the Supreme Judicial Court of the Commonwealth of Massachusetts held that “in order to justify a right to recover, a plaintiff asserting an error of the type Glenn asserts in this case [failure to object to a faulty jury instruction] must prove by a preponderance of the evidence, not only that the negligence of the attorney defendant caused his harm, but also that he is innocent of the crime charged.” The defendant urges us to adopt this heightened standard for malpractice claims against the criminal defense bar.

2002In Glenn v. Aiken, 409 Mass. 699 , 569 N.E.2d 783, 788 (1991), the Supreme Judicial Court of the Commonwealth of Massachusetts held that “in order to justify a right to recover, a plaintiff asserting an error of the type Glenn asserts in this case [failure to object to a faulty jury instruction] must prove by a preponderance of the evidence, not only that the negligence of the attorney defendant caused his harm, but also that he is innocent of the crime charged.” The defendant urges us to adopt this heightened standard for malpractice claims against the criminal defense bar.

11
Lutz Engineering Co. v. Industrial Louvers, Inc.green
ri · 1991 · cited in 1 Rhode Island opinions naming this issue, 1994–1994
1 sentence

1994We find that the trial justice’s proximate-cause instruction was “too subtle to inform the jurors fully [of their obligations].” Lutz Engineering Co. v. Industrial Louvers, Inc., 585 A.2d 631, 637 (R.I.1991).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (7)

CaseCitedYears
Mead v. Adrian green
iowa · 2003
1 sentence

2008Rather than prove proximate cause, “the plaintiff need only establish that ‘defendant’s negligence was a proximate cause of the lost chance to avoid the ultimate harm.’ ” Contois, 865 A.2d at 1023 (quoting Mead, 670 N.W.2d at 186 ).

12008–2008
cluster 718203 green
ca3 · 1996
1 sentence

1999Each has a different history of cigarette smoking, a factor that complicates the causation inquiry.'" Id. (quoting Georgine v. Amchem Products, Inc. , 83 F.3d 610 , 626 (3rd Cir. 1996).

11999–1999
Amchem Products, Inc. v. Windsor green
scotus · 1997
1 sentence

1999Each has a different history of cigarette smoking, a factor that complicates the causation inquiry.'" Id. (quoting Georgine v. Amchem Products, Inc. , 83 F.3d 610 , 626 (3rd Cir. 1996).

11999–1999
Busby v. Crown Supply green
ca4 · 1990
1 sentence

1997The Court is persuaded primarily by the Circuit Court's analysis of Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 , 105 S.Ct. 3275 , 87 L.Ed.2d 346 (1985) and American Nat'l Bank Trust Company v. Haroco Inc., 473 U.S. 606 , 105 S.Ct. 3291 , 87 L.Ed.2d 437 (1985) (per curiam): "Rather than construing § 1962 (a) as imposing a direct injury requirement in § 1964 (c) actions, we believe that Sedima instructs us to employ a traditional causation analysis in determining whether a RICO plaintiff has been injured `by reason of a section 1962 violation." 896 F.2d, at 839 .

11997–1997
American Nat. Bank & Trust Co. of Chicago v. Haroco, Inc. green
scotus · 1985
2 sentences

1997The Court is persuaded primarily by the Circuit Court's analysis of Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 , 105 S.Ct. 3275 , 87 L.Ed.2d 346 (1985) and American Nat'l Bank Trust Company v. Haroco Inc., 473 U.S. 606 , 105 S.Ct. 3291 , 87 L.Ed.2d 437 (1985) (per curiam): "Rather than construing § 1962 (a) as imposing a direct injury requirement in § 1964 (c) actions, we believe that Sedima instructs us to employ a traditional causation analysis in determining whether a RICO plaintiff has been injured `by reason of a section 1962 violation." 896 F.2d, at 839 .

1997The Court is persuaded primarily by the Circuit Court's analysis of Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 , 105 S.Ct. 3275 , 87 L.Ed.2d 346 (1985) and American Nat'l Bank Trust Company v. Haroco Inc., 473 U.S. 606 , 105 S.Ct. 3291 , 87 L.Ed.2d 437 (1985) (per curiam): "Rather than construing § 1962 (a) as imposing a direct injury requirement in § 1964 (c) actions, we believe that Sedima instructs us to employ a traditional causation analysis in determining whether a RICO plaintiff has been injured `by reason of a section 1962 violation." 896 F.2d, at 839 .

11997–1997
Sedima, S. P. R. L. v. Imrex Co. green
scotus · 1985
2 sentences

1997The Court is persuaded primarily by the Circuit Court's analysis of Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 , 105 S.Ct. 3275 , 87 L.Ed.2d 346 (1985) and American Nat'l Bank Trust Company v. Haroco Inc., 473 U.S. 606 , 105 S.Ct. 3291 , 87 L.Ed.2d 437 (1985) (per curiam): "Rather than construing § 1962 (a) as imposing a direct injury requirement in § 1964 (c) actions, we believe that Sedima instructs us to employ a traditional causation analysis in determining whether a RICO plaintiff has been injured `by reason of a section 1962 violation." 896 F.2d, at 839 .

1997The Court is persuaded primarily by the Circuit Court's analysis of Sedima, S.P.R.L. v. Imrex Co., 473 U.S. 479 , 105 S.Ct. 3275 , 87 L.Ed.2d 346 (1985) and American Nat'l Bank Trust Company v. Haroco Inc., 473 U.S. 606 , 105 S.Ct. 3291 , 87 L.Ed.2d 437 (1985) (per curiam): "Rather than construing § 1962 (a) as imposing a direct injury requirement in § 1964 (c) actions, we believe that Sedima instructs us to employ a traditional causation analysis in determining whether a RICO plaintiff has been injured `by reason of a section 1962 violation." 896 F.2d, at 839 .

11997–1997
Youst v. Longo green
cal · 1987
2 sentences

1993The California Supreme Court elaborated on this need for a definite economic relationship between the plaintiff and a third party when it said, "as a matter of law, a threshold causation requirement exists for maintaining a cause of action for either tort; namely, proof that it is reasonably probable that the lost economic advantage would have been realized but for the defendant's interference." Youst v. Largo, 43 Cal.3d 64 , ___, 23 Cal.Rptr. 294 , ___, 729 P.2d 728 , 733 (1987).

1993The California Supreme Court elaborated on this need for a definite economic relationship between the plaintiff and a third party when it said, "as a matter of law, a threshold causation requirement exists for maintaining a cause of action for either tort; namely, proof that it is reasonably probable that the lost economic advantage would have been realized but for the defendant's interference." Youst v. Largo, 43 Cal.3d 64 , ___, 23 Cal.Rptr. 294 , ___, 729 P.2d 728 , 733 (1987).

11993–1993

Where else courts name it

TX 252 (1978–2026) CA 161 (1978–2026) PA 61 (1952–2026) IL 49 (1980–2025) IA 48 (1982–2023) MI 47 (1988–2026) MO 40 (1989–2024) OH 33 (1991–2023) UT 30 (1986–2026) MA 28 (1980–2025) OR 28 (1990–2024) NY 27 (1933–2024) MD 26 (1977–2022) AL 26 (1981–2025) MN 25 (1987–2026) LA 24 (1984–2019) NM 23 (1938–2024) CT 22 (1991–2025) WA 22 (1983–2023) FL 21 (1984–2025) NJ 19 (1990–2026) WI 19 (1995–2024) GA 18 (1902–2025) SD 16 (1992–2020) VA 13 (1988–2024) CO 13 (1984–2020) AZ 13 (1997–2024) AK 12 (1988–2022) DC 12 (1990–2024) ID 12 (2005–2026) MT 11 (1990–2022) IN 11 (1986–2026) TN 11 (1997–2019) VT 10 (1991–2024) NC 10 (1988–2020) HI 9 (1995–2018) KS 9 (1991–2025) ME 8 (1982–2021) WY 8 (1982–2013) NE 8 (1996–2026) RI 7 (1993–2008) NH 7 (1986–2021) MS 7 (1992–2011) AR 6 (1999–2025) DE 4 (2014–2024) KY 3 (2006–2026) WV 2 (1997–2001) NV 2 (2012–2026) OK 2 (1981–2016) ND 2 (1994–2010)

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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