Eaton v. Davis’s Empirical Analysis
1940
Citation profile
10 federal appellate · 99 state decisions
How this case has been cited
Cited by 120 later decisions — most recently February 2018 · most notably Mullen v. Mullen (1948), Starnes v. Cayouette (1992)
10 federal appellate · 99 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 Audubon v. Shufeldt · Livingston v. . Livingston · Gloth v. Gloth · Capell v. Capell · Isaacs v. Isaacs
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 120 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“a statute will be construed in such a manner as to avoid a constitutional question wherever this is possible.”
5 later decisions quote this exact passage · from the majority“. . . the word alimony comes from the Latin alimonia, meaning `sustenance', and, as applicable here, the sustenance or support of the wife by her divorced husband. `It stems from the common-law right of the wife to support by her husband, which right, unless the wife by her own misconduct forfeits it, continues to exist even after they cease to live together. Alimony has as its sole object the support of the wife, and is not to be considered a property settlement upon a dissolution of the marriage.' (Emphasis supplied.) Eaton v. Davis [ 176 Va. 330 , 10 S.E.2d 893, 897 (1938)].”
3 later decisions quote this exact passage · from the majority“* * * Upon decreeing the dissolution of a marriage, and also upon decreeing a divorce, whether from the bond of matrimony or from bed and board, and upon decreeing that neither party is entitled to a divorce the court may make such further decree as it shall deem expedient concerning the estate and the maintenance of the parties, or either of them, and the care, custody and maintenance of their minor children, and may determine with which of the parents the children or any of them shall remain.”
2 later decisions 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.