Barrett v. Barrett’s Empirical Analysis
1977
Citation profile
122 state decisions
How this case has been cited
Cited by 122 later decisions — most recently May 2025 · most notably 378 Pa. Super. 474 - Sonder v. Sonder (1988), Commonwealth v. Marcone (1980)
122 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 Shillitani v. United States · Williams v. Illinois · Tate v. Short · Maggio v. Zeitz · First National Bank in Plant City v. Dickinson
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 122 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[Wjhere, as here, the court in civil proceedings finds there has been willful noncompliance with its earlier support orders constituting contempt but the contemnor presents evidence of his present inability to comply and make up the arrears, the court, in imposing coercive imprisonment for civil contempt, should set conditions for purging the contempt and effecting release from imprisonment with which it is convinced beyond a reasonable doubt, from the totality of the evidence before it, the contemnor has the present ability to comply. Since to condition a person’s avoidance of or release from imprisonment on his performing acts beyond his power to perform is in effect to convert a coercive sentence into a penal one without the safeguards of criminal procedure, we are of the opinion that the stricter evidentiary standard of the criminal law should apply with regard to the issue of present ability. (Citations omitted). Id. 470 Pa. at 621, 368 A.2d at 621. See also; Muraco v. Pitulski, 470 Pa. 269 , 368 A.2d 624 (1977).”
6 later decisions quote this exact passage““[T]he crucial question is not whether he willfully and contemptuously violated the original orders, but whether he had the present ability to comply with the conditions set by the court for purging himself of his contempt. ” 368 A.2d at 620 .”
3 later decisions quote this exact passage“"The use of the power to enforce compliance is exercised with the objective of compelling performance and not inflicting punishment.” In accordance with this principle, we have indicated that a court may, not convert a coercive sentence into a punitive one by imposing conditions that the contemnor cannot perform and thereby purge himsélf of the contempt.”
2 later decisions 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.