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← 347 Ark. 476 - Mayberry v. Flowers

Mayberry v. Flowers’s Empirical Analysis

2002

Citation profile

28
cited by 28 later decisions
1
states following
March 2024
most recently cited

2 district · 26 state decisions

How this case has been cited

Cited by 28 later decisions — most recently March 2024 · most notably McAdams v. McAdams (2003), Monday v. Canal Insurance (2002)

2 district · 26 state decisions

140200220102020decided

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 Armstrong v. Manzo · Grannis v. Ordean · Pender v. McKee · Blunt v. Cartwright · Woodson v. Lee

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

  1. “In holding as we do in this case, we are not unmindful of the need for finality in adoptions and the strict construction that must be accorded the one-year limitation period in section 9-9-216. We are, however, equally aware that the right of a natural parent to the custody of his or her child is “one of the highest of natural rights.” Due process requires, at a minimum, notice reasonably calculated to afford a natural parent the opportunity to be heard before his or her parental rights are terminated through adoption; Thus, before actual notice may be deemed an adequate substitute for the notice required by section 9-9-212 and Rule 4, it must be gained prior to the entry of the adoption decree. Knowledge after the decree is entered, even if it is gained within the one-year limitations period, will not suffice.”
    1 later decision quote this exact passage
  2. “The requirements of due process of law under [ Armstrong v. Manzo, 380 U.S. 545 , 85 S.Ct. 1187 , 14 L.Ed.2d 62 ,] were that she have notice reasonably calculated to apprise her of the pendency of the action and to afford her an opportunity to present her objections. These requirements of due process were met. We have heretofore recognized that one who was apprised of the pendency of an action and aware of the nature of the relief sought before a judgment was rendered, was not entitled to have the judgment vacated, whether process was served on him or not.”
    1 later decision quote this exact passage
  3. “whose consent to the adoption is required”
    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.