107 Ohio App. 3d 100 - Smith v. Collins’s Empirical Analysis

Citation profile

13 state decisions

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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “when a party voluntarily agrees to a child support obligation which exceeds the statutory support schedule by more than ten percent, that party must show a substantial change of cireumstances beyond the statutory ten percent deviation before the trial court may modify the support obligation”

   3 later decisions quote this exact passage
   e.g. In Re Marriage of Henson, 2006-T-0065 (8-24-2007) · Bonner v. Bonner, Unpublished Decision (11-21-2005)

2. “Any error in the trial court's adoption of the agreed entry, however, has been waived because neither party timely appealed that order. Nevertheless, this opinion should not be read as an endorsement of the procedures followed by the trial court. Rather, a trial court must include findings of fact in every child support order that deviates from the support schedule, even if the child support order is contained in a separation agreement or agreed journal entry adopted by the court. In this case, though, since neither party timely appealed the agreed entry, that entry must be accepted as the existing child support of the court.”

   1 later decision quote this exact passage
   e.g. In Re Marriage of Henson, 2006-T-0065 (8-24-2007)

3. “[a] deviation of ten percent in the amount to be paid between the original support order and the recalculated amount under the current circumstances is deemed to be a `change of circumstance substantial enough to require a modification of the child support amount.'”

   1 later decision quote this exact passage
   e.g. In Re Marriage of Henson, 2006-T-0065 (8-24-2007)