Ulsaker v. White’s Empirical Analysis
2006
Citation profile
35 state decisions
How this case has been cited
Cited by 35 later decisions — most recently July 2025 · most notably Hitz v. Hitz (2008), Holden v. Holden (2007)
35 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 Heley v. Heley · Kautzman v. Kautzman · Grinaker v. Grinaker · Hoge v. Hoge · Sack v. Sack
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 35 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“the respective ages of the parties, their earning ability, the duration of the marriage and conduct of the parties during the marriage, their station in life, the circumstances and necessities of each, their health and physical condition, their financial circumstances as shown by the property owned at the time, its value at the time, its income-producing capacity, if any, whether accumulated before or after the marriage, and such other matters as may be material. The trial court is not required to make specific findings, but it must specify a rationale for its determination.”
9 later decisions quote this exact passagee.g. Berg v. Berg · Lee v. Lee“[A] trial court must start with a presumption that all property held by either party whether held jointly or individually is to be considered marital property. The trial court must then determine the total value of the marital estate in order to make an equitable division of property.”
3 later decisions quote this exact passagee.g. Berg v. Berg · Lee v. Lee“Section 14-05-24.1, N.D.C.C., provides, “Making into consideration the circumstances of the parties, the court may require one party to pay spousal support to the other party for any period of time.” An award of spousal support is to be based on consideration of the Ruff-Fischer guidelines. Sack v. Sack, 2006 ND 57, ¶ 11 , 711 N.W.2d 157 ; Staley v. Staley, 2004 ND 195, ¶ 8 , 688 N.W.2d 182 . A separate finding that a spouse is “disadvantaged” is not necessary for an award of spousal support. Sack v. Sack, 2006 ND 57, ¶¶ 11-12 , 711 N.W.2d 157 . We have recognized that a difference in earning power should be considered when determining spousal support. Sommers v. Sommers, 2003 ND 77, ¶ 17 , 660 N.W.2d 586 . Property division and spousal support ordinarily must be examined and dealt with together. Id. at ¶ 15.”
1 later decision quote this exact passagee.g. Hagel v. Hagel
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.