Kulstad v. Maniaci’s Empirical Analysis
2009
Citation profile
2 district · 69 state decisions
How this case has been cited
Cited by 71 later decisions — most recently September 2025 · most notably In re the Parenting of N.S. (2011), In re C.J. (2010)
2 district · 69 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 Stanley v. Illinois · Troxel v. Granville · Matter of Guardianship of Doney · Polasek v. Omura · In Re ARA
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 71 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“(a) the natural parent has engaged in conduct that is contrary to the child-parent relationship; and (b) the nonparent has established with the child a child-parent relationship, as defined in 40-4-211, and it is in the best interests of the child to continue that relationship.”
3 later decisions quote this exact passage · from the dissent
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.