136 Ohio App. 3d 599 - Rohrbaugh v. Rohrbaugh’s Empirical Analysis
2000
Citation profile
130 state decisions
How this case has been cited
Cited by 130 later decisions — most recently January 2026 · most notably Brammer v. Brammer (2011), 171 Ohio App. 3d 650 - Lindman v. Geissler (2007)
130 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 Blakemore v. Blakemore · State v. Dehass · Davis v. Flickinger · Miller v. Miller · Booth v. Booth
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 130 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“an event, occurrence, or situation which has a material and adverse effect upon a child.”
14 later decisions quote this exact passage“(E) (1) (a) The court shall not modify a prior decree allocating parental rights and responsibilities for the care of children unless it finds, based on facts that have arisen since the prior decree or that were unknown to the court at the time of the prior decree, that a change has occurred in the circumstances of the child, the child's residential parent, or either of the parents subject to a shared parenting decree, and that the modification is necessary to serve the best interest of the child. In applying these standards, the court shall retain the residential parent designated by the prior decree or the prior shared parenting decree, unless a modification is in the best interest of the child and one of the following applies: {¶ 33} "* * * {¶ 34} "(iii) The harm likely to be caused by a change of environment is outweighed by the advantages of the change of environment to the child.”
2 later decisions quote this exact passage“Additionally, R.C. 3109.04(E)(1)(a) creates a rebuttable presumption that retaining the residential parent designated by the prior decree is in the child's best interest.”
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.