Sonnenberg v. Sonnenberg’s Empirical Analysis

Citation profile

9 state decisions

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 9 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “The child support guidelines define “net income” as an obligor’s gross annual income less federal and state tax obligations and other, expenses. N.D. Admin. Code § 75-02-04.1-01(7), [see N.D. Admin. Code § 75-02-04.1-01(6) (eff. July 1, 2011) ]. , In calculating child support, a district court must. consider “[n]et income. received by an obligor from all sources,..,” N.D. Admin. Code § 75-02-04.1-02(3)_ If an obligor’s income has changed in the recent past, or is likely to change in the near future, “consideration may be given to the new 'or likely future circumstances.” N.D. Admin. Code § 75-02-04.1-02(8). However, “unless the trial court makes a determination that evidence of an obli-gor’s recent past circumstances is not a reliable indicator of his future circumstances, the trial court must not extrapolate an obligor’s income under N.D. Admin. Code § 75-02-04.1-02(8).” [Korynta v. Korynta ], 2006 ND 17, ¶ 17 , 708 N.W.2d 895 . Therefore, unless the district court makes a specific finding that the income reflected on the prior year’s tax return is not a reliable indicator of future income, “[i]t is improper to calculate an obligor’s annual employment income based on a mid-year pay stub. Berge v. Berge, 2006 ND.46. ¶ 19, 710 N.W.2d 417 .”

   1 later decision quote this exact passage
   e.g. Brouillet v. Brouillet

2. ““ ‘Child support determinations involve questions of law which are subject to the de novo standard of review, findings of fact which are subject to the clearly erroneous standard of review, and may, in some limited areas, be matters of discretion subject to the abuse of discretion standard of review.’ ” Verhey v. McKenzie, 2009 ND 35, ¶ 5 , 763 N.W.2d 113 (quoting Buchholz v. Buchholz, 1999 ND 36, ¶ 11 , 590 N.W.2d 215 ). “A court errs as a matter of law if it does not comply with the requirements of the child support guidelines.” Doepke v. Doepke, 2009 ND 10, ¶ 6 , 760 N.W.2d 131 .”

   1 later decision quote this exact passage
   e.g. Entzie v. Entzie