Annie Andrews v. Kate H Andrews’s Empirical Analysis
Citation profile
5 federal appellate · 4 district · 173 state decisions
How this case has been cited
Cited by 202 later decisions (5 by the Supreme Court) — most recently February 2025 · most notably Williams v. State of North Carolina (1945), United States ex rel. Attorney General of the United States v. Delaware & Hudson Co. (1909)
5 federal appellate · 4 district · 173 state decisions — followed in 36 states
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 Maynard v. Hill · Thompson v. Whitman · Stone v. Mississippi · Frederick Bell v. Mary G Bell · William M'Elmoyle for the Use of Isaac Bailey v. John J Cohen
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 202 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““ ‘ Sec. 35. A divorce decreed in another State or country according to the laws thereof by a court having jurisdiction of the cause and of both the parties, shall be valid and effectual in this Commonwealth; but if an inhabitant of this Commonwealth goes into another State or country to obtain a divorce for a cause which occurred here, while the parties resided here, or for a cause which would not authorize a divorce by the laws of this Commonwealth, a divorce so obtained shall be of no force or effect in this Commonwealth. ’ 2 Rev. Laws Mass. 1902, ch. 152, p. 1357; Pub. Stat. 1882, c. 146, § 41.””
1 later decision quote this exact passage · from the majoritye.g. Glaser v. Glaser““It is equally clear that the statute prohibits an inhabitant of Massachusetts from going into another state to obtain a divorce, for a cause which occurred in Massachusetts while the parties were domiciled there, or for a cause which would not have authorized a divorce by the law of Massachusetts; and that the statute forbids the courts of Massachusetts from giving effect to a judgment of divorce obtained in violation of these prohibitions. That the statute establishes a rule of public policy is undeniable.””
1 later decision quote this exact passage · from the majority““We think it clear that the jurisdiction of the court by which a judgment is rendered in any state may be questioned in a collateral proceeding in another state, notwithstanding the provision of the 4th article of the Constitution, and the law of 1790, and notwithstanding the averments contained in the record of the judgment itself.””
1 later decision quote this exact passage · from the majoritye.g. State v. Wenzel
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.