Vanderbilt v. Vanderbilt’s Empirical Analysis
1957
Citation profile
79 federal appellate · 21 district · 447 state decisions
How this case has been cited
Cited by 624 later decisions (16 by the Supreme Court) — most recently May 2019 · most notably Hanson v. Denckla (1958), Zenith Radio Corp. v. Hazeltine Research, Inc. (1969)
79 federal appellate · 21 district · 447 state decisions — followed in 39 states
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
Applies 28 U.S.C. § 1738
Relies on Milliken v. Meyer · Pennoyer v. Neff · Williams v. State of North Carolina · Williams v. State of North Carolina · May v. Anderson
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 624 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“`It has long been the constitutional rule that a court cannot adjudicate a personal claim or obligation unless it has jurisdiction over the person of the defendant.'”
10 later decisions quote this exact passage · from the majority““When a husband has secured a judgment or decree of divorce * * * in an action * * * brought in this state or elsewhere, wherein jurisdiction over the person of the wife was not obtained, the court may make * * * orders * * * touching the suitable support and maintenance * * * for the wife * * * as the nature of the case and circumstances of the parties render suitable and proper * * * notwithstanding the securing of such judgment or decree.””
2 later decisions quote this exact passage · from the dissent““Despite the apparent finality of the Estin and Vanderbilt decisions, a rearguard action has been fought against the doctrine of divisible divorce itself. Mr. Justice Jackson, who dissented each time the doctrine was applied, never reconciled himself to the idea of ex parte divorce, regarding it as ‘a concept as perverse and unrealistic as an ex parte marriage,’ and a repudiation of procedural due process, imposing on the absent spouse a choice between defaulting on the merits or traveling to a distant state whose laws favored divorce; divisible divorce was simply a ‘compensating confusion’ violative of the full faith and credit obligation. Mr. Justice Frankfurter, while accepting Estin on the ground that a prior support order was entitled to full faith and credit in the divorce forum, found no justification for permitting inchoate support rights to survive, and dissented in Vanderbilt.’’ 76 Harv. L. Rev. 1233 , at p. 1238”
1 later decision quote this exact passage · from the dissente.g. Pezzino v. Pezzino
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.