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← 447 N.W.2d 871 - Johnson v. Hunter

Johnson v. Hunter’s Empirical Analysis

1989

Citation profile

44
cited by 44 later decisions
15
states following
April 2017
most recently cited

5 federal appellate · 37 state decisions

How this case has been cited

Cited by 44 later decisions — most recently April 2017 · most notably Charchenko v. City of Stillwater (1995), Hall v. Lalli (1999)

5 federal appellate · 37 state decisions — followed in 15 states

3201989199020002010decided

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 Northern Pipeline Construction Co. v. Marathon Pipe Line Co. · Weber v. Aetna Casualty & Surety Co. · Gomez v. Perez · 7 Va. App. 614 - Com., Dept. of Social Services v. Johnson · 91 Cal. App. 3d 271 - Ruddock v. Ohls

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

  1. “[u]nless a child's specific interests are addressed on the merits, a separate cause of action will be available to such child in another proper action.”
    2 later decisions quote this exact passage
  2. “While the state’s interest in paternity actions is primarily to prevent the child from “becompng] a public charge” by securing child support “[a] child’s interests are much broader.” For example, [child] points to several rights unique to her as a child, including: inheritance; medical support; causes of action; workers’ compensation dependent’s allowances; and veteran’s education benefits. Unlike the state’s interests, there may be psychological and emotional benefits to the child from an accurate establishment of paternity. * * * * * * Because [child] was not named as a party and was unrepresented in the 1969 action and because the issue of parentage has never been reached, it is difficult to say she had an adequate opportunity to be heard when her mother failed to appear for trial. At that point their interests differed. * * * [W]e now feel [that policies of finality and consistency] are outweighed in this context by the paramount interests of a child in an adjudication on the merits of paternity.”
    1 later decision quote this exact passage
  3. “A mother may have a variety of reasons for not initiating paternity proceedings: she may have a continuing relation with or affection for the father; she may wish to avoid continuing any relation with the father, including child support; she may wish to avoid the disapproval of her family or the community that she believes a paternity action would produce; she may be subject to the emotional strain and confusion that often attend the birth of a child born out of wedlock and continue for a prolonged period, hindering any effort by her to seek child support; she may be able to support the child and not foresee a change in her circumstances.”
    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.