Combs v. Edmiston’s Empirical Analysis

Citation profile

25 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 25 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “‘. . . that the trend of the more recent authority is toward the position that where a natural parent has freely and knowingly given the requisite consent to the adoption of his or her child, and the proposed adoptive parents have acted upon such consent by bringing adoption proceedings, the consent is ordinarily binding upon the natural parent and cannot be arbitrarily withdrawn so as to bar the court from decreeing the adoption, particularly where, in reliance upon such consent, the proposed adoptive parents have taken the child into their custody and care for a substantial period of time, and bonds of affection, in the nature of a “vested right,” have been forged between them and the child.”

   2 later decisions quote this exact passage
   e.g. Bruce v. Dillahunty · A. v. B.

2. “‘The rule in a majority of the jurisdictions wherein the question has arisen is that a natural parent’s consent to the proposed adoption of a child, duly given in compliance with a statute requiring such consent as a prerequisite to an adoption, may be effectively withdrawn or revoked by the natural parent before the adoption has been finally approved and decreed by the court.’”

   1 later decision quote this exact passage
   e.g. Bruce v. Dillahunty

3. “that it would be to the best interest of both the child and the appellants [adopting parents] to deny the adoption.”

   1 later decision quote this exact passage
   e.g. 19 Utah 2d 311 - D____ P____ v. Social Service & Child W. Dept.