1 Va. App. 358 - Simmons v. Simmons’s Empirical Analysis
1986
Citation profile
53 state decisions
How this case has been cited
Cited by 53 later decisions — most recently November 2014 · most notably 3 Va. App. 15 - Martin v. Pittsylvania County Department of Social Services (1986), 5 Va. App. 414 - Peple v. Peple (1988)
53 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 Brown v. Brown · Gray v. Gray · Carpenter v. Carpenter · Florance v. Florance · Durrette v. Durrette
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 53 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The case is rare in which the removal of children from their noncustodial parent’s [place] of residency does not result in some detriment. A child’s development is best facilitated in an atmosphere of stability, love, and concern. This is especially true when that love and concern flows from both parents. Oftentimes, the removal of children from the [place] of residency of one of those parents makes it more difficult for the absent parent to express and demonstrate such love and concern. The relationship between parent and a developing child, no matter how close, affectionate, or demonstrative, naturally suffers as the distance between the two increases. As such, questions of custody and removal from the noncustodial parent’s [place] of residency involve a balancing of interests. More often than not there are advantages and detriments on both sides of the issue. A trial court’s role is to weigh those concerns and conscientiously seek the solution that serves the best interest of the children.”
1 later decision quote this exact passagee.g. Lingsch v. Walker“The test that should have been applied has two prongs: first, has there been a change in circumstances since the most recent custody award; second, would a change in custody be in the best interests of the children.”
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.