In re Whitaker’s Empirical Analysis
1988
Citation profile
103 state decisions
How this case has been cited
Cited by 103 later decisions — most recently February 2026 · most notably In re Adoption of Ridenour (1991), Braatz v. Braatz (1999)
103 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 Blakemore v. Blakemore · Warner v. Waste Management, Inc. · Mimkon v. Ford · 25 Ohio St. 3d 331 - In re Schmidt · Browning v. Tarwater
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 103 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"(1) The wishes of the child's parents regarding his custody; "(2) The wishes of the child regarding his custody if he is eleven years of age or older; "(3) The child's interaction and interrelationship with his parents, siblings, and any other person who may significantly affect the child's best interest; "(4) The child's adjustment to his home, school, and community; "(5) the mental and physical health of all persons involved in the situation."”
2 later decisions quote this exact passage“R.C. 3109.05(A) gives the Court authority to order child support in a divorce, dissolution, alimony or child support proceeding and (B) authorizes the Court to make orders of visitation including, in the discretion of the Court, orders to persons other than the parents having an interest in the welfare of the child. Certainly grandparents fall within that category.”
2 later decisions quote this exact passagee.g. In re Sotlar · In re Gibson“While it may be entirely appropriate for a child to testify in open court under these circumstances, it may be more effective for the child to testify in chambers or for the trial court to informally interview the child in camera. `Testifying puts the child in an awkward position at a time when he or she already feels the pull of conflicting loyalties. Where the child wants to testify, or where the attorney has decided that it is necessary, the issue becomes whether the child testifies from the stand or whether the judge may conduct an interview in camera.'”
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.