Koch v. Williams’s Empirical Analysis
1990
Citation profile
43 state decisions
How this case has been cited
Cited by 43 later decisions — most recently April 2017 · most notably In Re the Marriage of Thurmond (1998), State ex rel. Department of Human Services ex rel. Jones v. Baggett (1999)
43 state decisions — followed in 14 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
Relies on Ohler v. Ohler · 53 Or. App. 539 - In Matter of Marriage of Edmonds · Routledge v. Routledge · Heller v. Heller · 152 Wis. 2d 1 - Parker v. Parker
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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“"While it is true that the `change of circumstances' necessary to warrant modification is one based primarily on a change in financial circumstances, ... it is also true that not every change in financial circumstances justifies a modification.... When the change is voluntary or self-induced, no modification is warranted because the obligor, by voluntarily placing herself or himself in a less financially secure position, is without clean hands and precluded from seeking equity. Even though the law never requires impossibilities, NDCC § 31-11-05(22), one who voluntarily dissipates or reduces income is not protected either from the consequences of such conduct or by equitable maxims."”
2 later decisions quote this exact passagee.g. Meyer v. Meyer · Wheeler v. Wheeler“a child support obli-gor's incarceration for incest does not constitute a material change of cireumstances justifying a modification of child support payments.”
2 later decisions quote this exact passagee.g. Lambert v. Lambert · Davis v. Vance““A trial court’s determination on modification of child support is treated as a finding of fact subject to the clearly erroneous standard of review under Rule 52(a), NDRCivP. Bloom v. Fyllesvold, 420 N.W.2d 327 (N.D.1988). A finding of fact is clearly erroneous when, although there is some evidence to support it, the reviewing court is left with a definite and firm conviction that a mistake has been made. Id.””
1 later decision quote this exact passagee.g. Illies v. Illies
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.