31 Ohio App. 2d 63 - In Re Haun’s Empirical Analysis
1972
Citation profile
31 state decisions
How this case has been cited
Cited by 31 later decisions — most recently September 2020 · most notably In re Adoption of Charles B. (1990), State ex rel. Portage County Welfare Dept. v. Summers (1974)
31 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.
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"* * * [T]he requirement of agency consent was not intended by the legislature to give an unnatural parent an arbitrary, unreasonable or capricious power to defeat judicial review and, coincidentally, impede, in a specific case as in this instance, the objectives of securing qualified adoptive parents and promoting the best interests of a child available for adoption. Moreover, we find that refusal of consent even when it is not arbitrary, unreasonable or capricious does not deprive the Probate Division, Common Pleas Court, of jurisdiction. To the degree that it is reasonable, it does add an element for consideration in the Probate Court's determination of the qualifications of the adoptive parents and the best interests of the child."”
5 later decisions quote this exact passage““The trial court held that the refusal of consent, apparently without more, raised the question of the best interest of the child for adjudication. We find it unnecessary to go so far to support the trial court’s decision. It is enough, in our view, to simply subject the withholding of agency consent to judicial scrutiny to determine whether the agency is acting unreasonably, arbitrarily, or capriciously.””
2 later decisions quote this exact passage“agency consent becomes superior to all other considerations, even those which ... are clearly of the gravest importance to the whole adoption program.”
2 later decisions 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.