1 N.C. App. 108 - In Re Holt’s Empirical Analysis
1968
Citation profile
28 state decisions
How this case has been cited
Cited by 28 later decisions — most recently May 2002 · most notably Oxendine v. Catawba County Department of Social Services (1981), 14 N.C. App. 378 - Johnson v. Johnson (1972)
28 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 In Re the Custody of Sauls · McLean v. McLean · Blankenship v. Blankenship · Wilson v. Commissioners of Bladen County
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 28 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““An action or proceeding in the courts of this State for custody and support of a minor child may be maintained in the county where the child resides or is physically present or in a county where a parent resides, except as hereinafter provided. If an action for annulment, for divorce, either absolute or from bed and board, or for alimony without divorce has been previously instituted in this State, until there has been a final judgment in such case, any action or proceeding for custody and support of the minor children of the marriage shall be joined with such action or be by motion in the cause in such action.” (Emphasis ours.)”
3 later decisions quote this exact passage“[A]fter final judgment in a previously instituted action between the parents, where custody and support has not been brought to issue or determined, the custody and support issue may be determined in an independent action in another court.... Of course, if the custody and support has been brought to issue or determined in the previously instituted action between the parents, there could be no final judgment in that case, because the issue of custody and support remains in fieri until the children have become emancipated. 27B C.J.S. 423; 27B C.J.S. 678.”
3 later decisions quote this exact passage“not been brought to issue or determined,”
2 later decisions 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.