Volz v. Peterson’s Empirical Analysis
2003
Citation profile
14 state decisions
How this case has been cited
Cited by 14 later decisions — most recently January 2026
14 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 Kelly v. Kelly · Mosbrucker v. Mosbrucker · Alvarez v. Carlson · Gietzen v. Gietzen · O'Neill v. O'Neill
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 14 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“A party seeking modification of a custody order shall serve and file moving papers and supporting affidavits and shall give notice to the other party to the proceeding who may serve and file a response and opposing affidavits. The court shall consider the motion on briefs and without oral argument or evidentiary hearing and shall deny the motion unless the court finds the moving party has established a prima facie case justifying a modification. If a prima facie case is established, the court shall set a date for an evidentiary hearing.”
3 later decisions quote this exact passagee.g. Hawley v. LaRocque · Lagro v. Lagro“[t]he modification is necessary to serve the best interest of the child.”
2 later decisions quote this exact passagee.g. Hawley v. LaRocque · Frueh v. Frueh“Unless the opposing party’s counter-affidavits conclusively show the moving party’s allegations have no credibility or are insufficient to justify modification of primary residential responsibility, an evi-dentiary hearing must be held to resolve conflicting evidence and determine whether a modification of primary residential responsibility is warranted.”
1 later decision quote this exact passagee.g. Jensen v. Jensen
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.