Lenherr Estate’s Empirical Analysis
1974
Citation profile
6 federal appellate · 5 state decisions
How this case has been cited
Cited by 17 later decisions — most recently September 2025
6 federal appellate · 5 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 Griffith v. United Air Lines, Inc. · Loughran v. Loughran · Estate of Stull · 163 Pa. Super. 264 - Maurer v. Maurer · 83 Cal. App. 2d 256 - Estate of Bir
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 17 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Specifically regarding conflicts as to recognition of marital status, there is a strong policy favoring uniformity of re- suit. In an age of widespread travel and ease of mobility, it would create inordinate confusion and defy the reasonable expectations of citizens whose marriage is valid in one state to hold that marriage invalid elsewhere. On the other hand, each state may, within constitutional limits, create laws and procedures concerning the sanctification of marriages ... and those laws and procedures should not be circumvented by the sham of traveling to a nearby less stringent jurisdiction.”
1 later decision quote this exact passage“The husband or wife, who shall have been guilty of the crime of adultery, shall not marry the person with whom the said crime was committed, during the life of the former wife or husband: but nothing herein contained shall be construed to extend to or affect or render other than legitimate any children born of the body of the wife during coverture.”
1 later decision quote this exact passagee.g. Chlystek v. Califano“(1) could deter either the adulterous conduct during the valid marriage or the subsequent marriage of the guilty spouse and his or her paramour; or (2) could in any way spare the aggrieved former spouse the affront caused by such marriage.”
1 later decision quote this exact passagee.g. Chlystek v. Califano
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.