117 N.C. App. 369 - Benedict v. Coe’s Empirical Analysis
1994
Citation profile
12 state decisions
How this case has been cited
Cited by 12 later decisions — most recently May 2011
12 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 Domingues v. Johnson · Clark v. Clark · 52 N.C. App. 203 - Falls v. Falls · Matter of Custody of Peal · 107 N.C. App. 71 - Ramirez-Barker v. Barker
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 12 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Our courts have held that the modification of a custody decree must be supported by findings of fact based on competent evidence that there has been a substantial change of circumstances affecting the welfare of the child, and the party moving for such modification assumes the burden of showing such change of circumstances.”
1 later decision quote this exact passage“[t]he court need not wait for any adverse effects on the child to manifest themselves before the court can alter custody. It is neither necessary nor desirable to wait until the child is actually harmed to make a change in custody.”
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.