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← 294 Md. 605 - Thomas v. Thomas

Thomas v. Thomas’s Empirical Analysis

1982

Citation profile

45
cited by 45 later decisions
2
states following
November 2009
most recently cited

2 federal appellate · 43 state decisions

How this case has been cited

Cited by 45 later decisions — most recently November 2009 · most notably Taylor v. Taylor (1986), Horsey v. Horsey (1993)

2 federal appellate · 43 state decisions

210198219902000decided

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 Dougherty v. Dougherty · Dickey v. Dickey · Emerson v. Emerson · Hood v. Hood · Grinder v. Bryans Road Building & Supply Co.

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 45 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The Thomas Court said: [T]he court found that $1,700 in alimony arrearage was owed by Carlos Thomas; however, this amount was offset with money left in a bank account by Carlos which Ida Thomas expended, resulting in an $800 alimony overpay ment. As to the period of reconciliation (December 4, 1977, to March 17, 1978), the court found that Mr. Thomas “was not obligated to pay alimony” because “it seems clear that alimony is not to continue upon cohabitation and that reconciliation causes alimony to cease during the period of reconciliation.” The court alternatively held that “the parties’ reconciliation constituted a substantial change in circumstances justifying modification.””
    1 later decision quote this exact passage · from the majority
  2. “In England, during the seventeenth and eighteenth centuries, courts did not grant absolute divorces (divorce a vinculo matrimonii), but the ecclesiastical courts would grant divorces from bed and board (divorce a mensa et thoro). Incidental to the a mensa divorce, the ecclesiastical courts could award alimony to the wife. Nevertheless, for most of this period, alimony had no independent exis tence under English law; it could be awarded only by an ecclesiastical court and only as part of a divorce decree. This English “doctrine was adopted and followed in ... many of the States in this country, but not in Maryland.””
    1 later decision quote this exact passage · from the majority
  3. “[T]he relationship between divorce and alimony under the English law was adopted in some areas of this country but not in Maryland. Although under Maryland law divorce and alimony are tied together for certain purposes, alimony has never been viewed as an incident of divorce. Indeed, the jurisdiction of equity courts to grant alimony, unlike a divorce, was not based upon statute. Instead, the power to grant alimony was deemed to be within the inherent authority of Maryland equity courts.”
    1 later decision quote this exact passage · from the majority

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.