Willcox v. Bradrick’s Empirical Analysis
1982
Citation profile
11 state decisions
How this case has been cited
Cited by 11 later decisions — most recently December 2002
11 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 Spaulding v. Spaulding · Simpkins v. Simpkins · Wren v. Wren · Beasley v. Beasley · In Re the Marriage of Harless
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 11 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Section 598.21(8) does not specify the time at which modifications in the amount of child support are to become effective. The defendant argues the district court could not make the increase in child support retroactive to the date of the plaintiff’s application for modification, at least “in absence of manifest injustice.” He relies upon this language from Wren v. Wren, 256 Iowa 484 , 127 N.W.2d 643, 646 (1964): Modification of a decree for support payments operates prospectively and not retrospectively. The right to modify does not authorize the court to divest the parties of rights accrued under the original decree. Even where a decree is modified and a change is made payments that have accrued up to that time cannot thereby be affected. (Citations omitted.) See Delbridge v. Sears, 179 Iowa 526, 532-33 , 160 N.W. 218 , 221 (1916). Wren, however, did not establish when payments could be considered to be retroactive, viz., at the time of the filing of the application or at the time of the filing of the modification decree. This question was answered in Spaulding v. Spaulding, 204 N.W.2d 634, 636 (Iowa 1973), where the court stated a parent’s duty to pay increased child support as a result of a modification proceeding can be “made retroactive to ... the date [of the filing of] the application for modification....” See also Delbridge, 179 Iowa at 530, 533-34 , 160 N.W. at 221 (a dissolution decree is a finality “until the power of the court [is] invoked to make changes and mod”
1 later decision quote this exact passage“Upon every judgment of ... dissolution ... the court may order either parent or both parents to pay an amount reasonable and necessary for support of a 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.