241 Pa. Super. 53 - Schrock v. Schrock’s Empirical Analysis
1976
Citation profile
38 state decisions
How this case has been cited
Cited by 38 later decisions — most recently May 2025 · most notably 337 Pa. Super. 573 - Vajda v. Vajda (1985), 280 Pa. Super. 344 - Rollman v. Rollman (1980)
38 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 McKrell v. McKrell · Wick v. Wick · Steinke v. Steinke · Gehris v. Gehris · Boyer v. Boyer
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 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[I]t is our duty, on appeal to make an independent study of the record and to determine whether a legal cause of action for divorce exists. Barr v. Barr, 232 Pa.Super. 9 , 331 A.2d 774 (1974); Arcure v. Arcure, 219 Pa.Super. 415 , 281 A.2d 694 (1971). Moreover, while the master’s findings of fact and recommendation that a divorce be granted are only advisory, where the issue is one of credibility and the master is the one who heard and observed the witness, his findings should be given the fullest consideration. Gehris v. Gehris, 233 Pa.Super. 144 , 334 A.2d 753 (1975); Sells v. Sells, 228 Pa.Super. 331 , 323 A.2d 20 (1974).”
4 later decisions quote this exact passage“"Indignities may consist of vulgarity, unmerited reproach, habitual contumely studied neglect, intentional incivility, manifest disdain, abusive language, malignant ridicule, and every other plain manifestation of settled hate and estrangement."”
3 later decisions quote this exact passage“To make out a charge of indignities, three elements must be proved: (1) a course of conduct that, although varying according to the circumstances of each case, must in every case (2) be inconsistent with the marital relationship, and (3) render the condition of the innocent party intolerable and his or her life burdensome--- Although no general rule can be formulated as to what constitutes indignities in a particular case, the matter being one that depends upon all the circumstances of the particular case and the position in life, character, and disposition of the parties ... our cases hold that proof of “vulgarities, unmerited reproach, habitual contumely, studied neglect, intentional incivility, manifest disdain, abusive language, or malignant ridicule” may be sufficient to make out a case for divorce based on indigni-ties____ Moreover, several of these factors “may coalesce to justify a finding of indignities, although taken separately, no single incident or factor would be sufficient.” ... Finally, it should be noted that in the present case, the burden of proving indignities was on the husband as the party seeking the divorce ... and that the husband was required to prove that he was an innocent and injured spouse....”
1 later decision quote this exact passage
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.