Rosenberg v. Merida’s Empirical Analysis
1998
Citation profile
41 state decisions
How this case has been cited
Cited by 41 later decisions — most recently October 2022 · most notably Adams v. Adams (2011), Custody of Kali (2003)
41 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 City of Riverside v. National Environmental Waste Corp. · Cash v. Cash · Cohen v. Murphy · Weaks v. Weaks · Miller v. Miller
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 41 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The fairest approach for calculating the credit here is to treat the SSDI dependency benefits as if they were first paid directly to the noncustodial parent, who then pays that same amount to the custodial parent to satisfy some part of the support obligation. Specifically, the amount of the SSDI dependency benefits should be included in the income of the noncustodial parent and the guidelines should then be applied to that amount. As in any other determination of a proper support obligation, the judge may adjust the amount as calculated by this approach on making findings that such amount is unjust or inappropriate. The noncustodial parent is then allowed a credit equal to the amount of the SSDI dependency benefits. The net amount of the noncustodial parent’s support obligation thus is simply the difference between the support amount calculated above (or as adjusted by the judge) minus the amount of the credit.”
1 later decision quote this exact passage“To impose the requirement of a court proceeding, i.e., modification hearing, on a party seeking to credit disability payments received by the custodial parent for the benefit of the parties' children is overly harsh. In situations involving disability benefits, the party seeking credit most likely faces a reduction of income, financial uncertainty, physical or mental impairment and other attendant consequences of the disability. The additional burden of petitioning the court for a modification typically wastes time and money and helps no one.”
1 later decision quote this exact passage“[U]nlike welfare and other forms of public assistance, social security benefits represent contributions that a worker has made throughout the course of employment.... ... Although the benefits are payable directly to the child rather than through the contributing parent, the child’s entitlement to payments derives from the parent, and the payments themselves represent earnings from the parent’s past contributions.”
1 later decision quote this exact passagee.g. In re Angley-Cook
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.