152 Ohio App. 3d 174 - Bragg v. Hatfield’s Empirical Analysis
2003
Citation profile
56 state decisions
How this case has been cited
Cited by 56 later decisions — most recently March 2024 · most notably 181 Ohio App. 3d 167 - Purvis v. Hazelbaker (2009), In Re Estate of Osborne (2006)
56 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 Santosky v. Kramer · Troxel v. Granville · Davis v. Flickinger · In re Murray · In re Jane Doe 1
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 56 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(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 · from the majority“The change [of circumstances] must be significant — something more than a slight or inconsequential change.”
2 later decisions quote this exact passage · from the majority“A trial court's finding regarding a change in circumstances should not be disturbed on appeal absent an abuse of discretion. Davis v. Flickinger (1997), 77 Ohio St.3d 415 , 416 , 674 N.E.2d 1159 . An abuse of discretion is more than an error of law or judgment; it implies that the trial court's attitude was unreasonable, arbitrary, or unconscionable. See Landis v. Grange Mut. Ins. Co. (1998), 82 Ohio St.3d 339 , 342 , 695 N.E.2d 1140 ; Malone v. Courtyard by Marriott, L.P. (1996), 74 Ohio St.3d 440 , 448 , 659 N.E.2d 1242 ; State ex rel. Solomon v. Police Firemen's Disability Pension Fund Bd. of Trustees (1995), 72 Ohio St.3d 62 , 64 , 647 N.E.2d 486 . In applying the abuse-of-discretion standard, appellate courts are admonished that they are not to substitute their judgment for that of the trial court. See State ex rel. Duncan v. Chippewa Twp. Trustees (1995), 73 Ohio St.3d 728 , 732 , 654 N.E.2d 1254 ; In re Jane Doe 1 (1991), 57 Ohio St.3d 135 , 137-138 , 566 N.E.2d 1181 ; Berk v. Matthews (1990), 53 Ohio St.3d 161 , 169 , 559 N.E.2d 1301 . Indeed, to demonstrate an abuse of discretion, the result must be so palpably and grossly violative of fact or logic that it evidences not the exercise of will but the perversity of will, not the exercise of judgment but the defiance of judgment, not the exercise of reason but instead passion or bias. Nakoff v. Fairview Gen. Hosp. (1996), 75 Ohio St.3d 254 , 256 , 662 N.E.2d 1 .”
1 later decision quote this exact passage · from the majority
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.