Cunningham v. Gray’s Empirical Analysis
1981
Citation profile
17 state decisions
How this case has been cited
Cited by 17 later decisions — most recently February 2002
17 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 Malpass v. Morgan · Ward v. Faw
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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The record here ... is completely devoid of any evidence that continuation of the present limited relationship between Cunningham and his daughter, or any broadening of that relationship which may occur in the future, will be disruptive of the child’s well-being. The evidence shows that friction exists between the natural parents, that in the past the father’s occasional violence toward the mother upset the child, that the father has a poor employment record, and that he has been convicted of a minor crime. But there is no evidence which supports a finding that those negative factors will have a definitive adverse effect on the child’s welfare if the father-daughter relationship is continued. ( 221 Va. 795 ).”
2 later decisions quote this exact passage · from the majority“[w]here . . . there is no question of the fitness of the nonconsenting parent and he has not by conduct or previous legal action lost his rights to the child, it must be shown that continuance of the relationship between the two would be detrimental to the child’s welfare.”
2 later decisions quote this exact passage · from the majority“[W]hile the welfare of the child is of paramount concern in adoption cases, nonetheless the rights of a natural parent vis-a-vis a non-parent will be maintained if at all consistent with the child's best interests.”
1 later decision quote this exact passage · from the majoritye.g. Doe v. Doe
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.