103 Ark. App. 207 - Hicks v. Cook’s Empirical Analysis
2008
Citation profile
32 state decisions
How this case has been cited
Cited by 32 later decisions — most recently February 2025 · most notably 2011 Ark. App. 546 - Bamburg v. Bamburg (2011), Lamontagne v. Arkansas Department of Human Services (2010)
32 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 Ferguson v. Green · Hamilton v. Barrett · Taylor v. Taylor · Digby v. Digby · Taylor v. Taylor
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 32 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In Harmon v. Wells ... this court analyzed two cases that relied upon Arkansas Code Annotated section 9-10-113, and held that in order to determine which standard the trial court should use in a custody dispute involving parties who were not married at the time the child was born-best interests of the child (as is utilized for initial custody determinations) or material change of circumstances (which is used when custody is being changed)-the issue rests entirely on whether the initial order in the paternity action was permanent or temporary. If it was permanent, the trial court should follow Norwood v. Robinson ... and require a change of circumstances. If it was temporary, the trial court should follow Sheppard v. Speir ... and conclude that there is no need for the father to prove changed circumstances to obtain custody.”
1 later decision quote this exact passagee.g. Rivers v. DeBoer“Arkansas Code Annotated section 9-10-113(a) provides that an illegitimate child shall be in the custody of its mother unless a court of competent jurisdiction enters an order placing the child in the custody of another party. Section 9-10-113(b) provides that a biological father may petition the court for custody if he has established paternity in a court of competent jurisdiction. Custody may be awarded to a biological father upon a showing that (1) he is a fit parent to raise the child; (2) he has assumed his responsibilities toward the child by providing care, supervision, protection, and financial support for the child; and (3) it is in the best interest of the child to award custody to the biological father.”
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.