321 Pa. Super. 219 - Carangelo v. Carangelo’s Empirical Analysis

Citation profile

18 state decisions

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

1. “Pa.R.C.P. 1920.52(b) includes claims involving child support. Although neither Carangelo nor DeWalt involved child support, the reasoning of these cases may be read as applying to any claim provided for in Pa.R.C.P. 1920.52(b). Neither of the alternative (i.e., ‘office conference’) procedures for support actions, set forth in Pa.R.C.P. 1910.11 and 1910.12, allows the filing of exceptions to the final order. Pa.R.C.P. 1910.1 l(k), 1910.12(g). Some readers may therefore find an apparent conflict between these sections and the court’s reasoning in DeWalt and Carangelo . I don’t believe there is in fact any conflict. Application of the rule of statutory construction that a more specific provision prevails over a more general provision, 1 Pa.C.S. § 1933, shows that Pa.R.C.P. 1910.11(k) and 1910.12(g) would control the need to file exceptions in support actions conducted pursuant to these sections.”

   1 later decision quote this exact passage
   e.g. 338 Pa. Super. 203 - Baraff v. Baraff

2. “(b) In claims involving (1) child support, (2) alimony pendente lite, (3) counsel fees, costs and expenses, (4) an uncontested action of divorce, or (5) an uncontested action for annulment, the decision of the trial judge may consist only of general findings.”

   1 later decision quote this exact passage
   e.g. 344 Pa. Super. 465 - Szakmeister v. Szakmeister