Masitto v. Masitto’s Empirical Analysis
1986
Citation profile
201 state decisions
How this case has been cited
Cited by 201 later decisions — most recently October 2025 · most notably In re James (2007), Reynolds v. Goll (1996)
201 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 C. E. Morris Co. v. Foley Construction Co. · 52 Ohio St. 2d 89 - Perales v. Nino · 145 Ohio St. 82 - Clendenning v. McCall · 70 Ohio St. 2d 213 - State ex rel. Smith v. Court of Common Pleas · Reid v. Quigley
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 201 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““The court shall not modify a prior decree allocating parental rights and responsibilities for the care of children unless it finds, based on facts that have arisen since the prior decree or that were unknown to the court at the time of the prior decree, that a change has occurred in the circumstances of the child, his residential parent, or either of the parents subject to a shared parenting decree, and that the modification is necessary to serve the best interest of the child. In applying these standards, the court shall retain the residential parent designated by the prior decree or the prior shared parenting decree, unless a modification is in the best interest of the child and one of the following applies: “(in) The harm likely to be caused by a change of environment is outweighed by the advantages of the change of environment to the child.””
7 later decisions quote this exact passage · from the majority“[T]he determination of whether a 'parent relinquishes rights to custody is a question of fact which, once determined, will be upheld on appeal if there is some reliable, credible evidence to support the finding.'”
5 later decisions quote this exact passage · from the majoritye.g. In re Spriggs · In re A.L.“The general rule in Ohio regarding original custody awards in disputes between a parent and a non-parent is that “parents who are ‘suitable’ persons have a ‘paramount’ right to the custody of their minor children unless they forfeit that right by contract, abandonment, or by becoming totally unable to care for and support those children.””
4 later decisions quote this exact passage · from the majoritye.g. In Re S.M. · In re A.L.
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.