2 Va. App. 151 - Acree v. Acree’s Empirical Analysis
1986
Citation profile
44 state decisions
How this case has been cited
Cited by 44 later decisions — most recently November 2016 · most notably 44 Va. App. 287 - Cirrito v. Cirrito (2004), 18 Va. App. 154 - Commonwealth Ex Rel. Comptroller of Virginia v. Skeens (1994)
44 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 Cofer v. Cofer · Newton v. Newton · Fearon v. Fearon · Richardson v. Moore · Isler v. Isler
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 44 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“We are of the opinion that a narrow exception to the rule may exist in a case where the obligated party, by agreement with the custodial parent, has taken the child or children into his or her home, has assumed custody of them, has provided them with food, clothing, shelter, medical attention, and school supplies, and has exercised parental control over their activities and education for such an extended period of time that a permanent change of custody is demonstrated. In such a case, the court may, in its discretion, allow credit against the accrued support for the reason that the obligated parent has merely furnished support in a different manner under different circumstances easily susceptible of proof.”
2 later decisions quote this exact passage“custodial parent has by his or her own volition entered into an agreement to relinquish custody on a permanent basis and has further agreed to the elimination of support payments and such agreement has been fully performed, ... the purpose to be served by application of an inflexible rule denying credit for non-conforming payments is outweighed by the equities involved----By assuming [complete] physical custody and total responsibility for the support of the child, the husband fulfilled his obligation under the decree.”
2 later decisions quote this exact passage“We simply refuse to reward an individual who seeks to take advantage of an agreement entered into freely and voluntarily, after it had been fully performed to her benefit.... To enforce the letter of the decree after its purpose has been served and the parties’ agreement fully performed would unjustly enrich the wife and shock the conscience of the average person. Most important, failure to enforce the letter of this decree under these circumstances will not work to the detriment of the child, for whose benefit the support was to be paid. That agreement of the parties as carried out worked to the benefit of the child to the same degree that absolute conformity with the terms of the decree would have.”
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.