25 N.C. App. 90 - King v. Allen’s Empirical Analysis
1975
Citation profile
24 state decisions
How this case has been cited
Cited by 24 later decisions — most recently March 2010
24 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 Blackley v. Blackley · 21 N.C. App. 306 - Hensley v. Hensley · Todd v. Todd
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 24 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“N.C. Gen. Stat. § 50-13.7 (a) sets forth the criteria necessary to modify a custody order. It states in pertinent part: "(a) An order of a court of this state for custody of a minor child may be modified or vacated at any time, upon motion in the cause and a showing of changed circumstances by either party[.]" Thus, "once the custody of a minor child is judicially determined, that order of the court cannot be modified until it is determined that (1) there has been a substantial change in circumstances affecting the welfare of the child; and (2) a change in custody is in the best interest of the child." Since, there is a statutory procedure for modifying a custody determination, a party seeking modification of a custody decree must comply with its provisions. There are no exceptions in North Carolina law to the requirement that a change in circumstances be shown before a custody decree may be modified.”
1 later decision quote this exact passage“The trial judge, who has the opportunity to see and hear the parties and the witnesses, is vested with broad discretion in cases involving custody of children, his findings of fact in custody orders are binding on the appellate courts if supported by competent evidence . . . and his decision should not be upset absent a clear showing of an abuse of discretion.”
1 later decision quote this exact passage“[T]he party moving for modification of a custody order has the burden of showing that there has been a substantial change of circumstances affecting the welfare of the child.”
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.