Comulada v. Comulada’s Empirical Analysis
1964
Citation profile
26
cited by 26 later decisions
1
states following
December 1969
most recently cited
26 state decisions
Relationships
Relies on Schriver v. Schriver · Moran v. Moran · Kremelberg v. Kremelberg · Heinmuller v. Heinmuller · Zulauf v. Zulauf
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 26 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““A final decree of divorce [i] shall not be passed upon the testimony of the plaintiff alone, [ii] nor shall the admissions of a defendant in an action for divorce be taken of themselves as conclusive proof of the facts charged as the ground of the action, but [iii] in all cases testimony of a person not a party in corroboration of the plaintiff shall be required.””
3 later decisions quote this exact passage · from the majority““All of the cases hold that the testimony of the plaintiff must be corroborated and that corroboration cannot be dispensed with altogether. [Citing cases]. But in contested cases, where there is no possibility of collusion, it has been consistently held that only slight evidence is required to corroborate the testimony of the complaining spouse. [Citing cases]. “In some cases, such as Kremelberg v, Kremelberg, 52 Md. 553 (1879) and Fassett v. Fassett, 143 Md. 35 , 121 Atl. 859 (1923), decrees of divorce were granted on evidence consisting largely of admissions of adultery. In at least two cases, Maranto v. Maranto, 192 Md. 214 , 64 A. 2d 144 (1949) and Cullotta v. Cullotta, 193 Md. 374 , 66 A. 2d 919 (1949), it was stated, without any qualification as to its trustworthiness, that the corroboration required may be found in evidence of admissions by the other spouse. But in other cases in which it was held that admissions were acceptable as corroborative evidence, it was further pointed out that such evidence, unsupported by other proof, should be received with utmost circumspection and caution. See Schriver v. Schriver, 185 Md. 227 , 44 A. 2d 479 (1945) ; Zulauf v. Zulauf, 218 Md. 99 , 145 A. 2d 414 (1958).””
2 later decisions quote this exact passage · from the majoritye.g. Stewart v. Stewart · Soles v. Soles
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.