In Re Scott S.’s Empirical Analysis
2001
Citation profile
60 state decisions
How this case has been cited
Cited by 61 later decisions — most recently April 2025 · most notably In re Thomas H. (2005), In Re Thomas D. (2004)
60 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 Neder v. United States · In Re William S. · State v. DeMass · State v. Phillipo · Lawton v. Richmond
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 61 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(1) The parent consents to the termination...; or (2) The court finds, based on clear and convincing evidence, that: (a) Termination is in the best interest of the child; and (b) Either: (i)The parent is unwilling or unable to protect the child from jeopardy and these circumstances are unlikely to change within a time reasonably calculated to meet the child’s needs; (ii) The parent has been unwilling or unable to take responsibility for the child within a time which is reasonably calculated to meet the child’s needs; (iii) The child has been abandoned; or (iv) The parent has failed to make a good faith effort to rehabilitate and reunify with the child pursuant to section 4041.”
3 later decisions quote this exact passage · from the dissente.g. Adoption of L.E. · In Re Heather G.“[T]he State has the burden of persuading us that it is highly probable that the error did not prejudice the parents or contribute to the result in the case. The State’s burden of persuasion is high. Any doubt will be resolved in favor of the parent. Thus, when an error has occurred in a termination of parental rights proceeding, and the party alleging the error has preserved his or her objection to the error, we review the entire record to determine whether the error prejudiced the parents in the presentation of their case or had the potential to affect the outcome of the ease. In the absence of substantial certainty, that is, a determination that it is highly probable, that the error had no prejudicial effect and did not affect the outcome, we will vacate the judgment.”
1 later decision quote this exact passage · from the dissente.g. In Re Rachel J.
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.