In Re S.M.’s Empirical Analysis
2005
Citation profile
20 state decisions
How this case has been cited
Cited by 20 later decisions — most recently November 2023
20 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 Miller v. Miller · 52 Ohio St. 2d 89 - Perales v. Nino · Masters v. Masters · Masitto v. Masitto · Hockstok v. Hockstok
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 20 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[A] court may not award custody to the nonparent "without first determining that a preponderance of the evidence shows that the parent abandoned the child; contractually relinquished custody of the child; that the parent has become totally incapable of supporting or caring for the child; or that an award of custody to the parent would be detrimental to the child."”
2 later decisions quote this exact passage“a trial court abuses its discretion in awarding custody to a nonparent based solely on the child's best interest. Perales , supra at 96 . However, once an original custody award has been made, that award will not be modified unless it serves the best interest of the child. Id. {¶ 20} The mother first argues that the trial court's decision must be reversed because the trial court failed to make a finding of unsuitability with regard to the father as required under Perales. The record, however, reflects that the trial court expressly found that the father”
1 later decision quote this exact passage“the state may *Page 9 infringe upon the fundamental parental liberty interest of child 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.