Mullins’s Empirical Analysis
Citation profile
10 state decisions
How this case has been cited
Cited by 31 later decisions — most recently April 2025 · most notably 58 Cal. App. 4th 721 - Department of Social Services v. Superior Court of Siskiyou County (1997), State in Interest of Hj (1999)
10 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 Board of Regents of State Colleges v. Roth · Younger v. Harris · District of Columbia Court of Appeals v. Feldman · Rooker v. Fidelity Trust Co. · Railroad Commission v. Pullman Co.
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 31 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Neither the text nor the structure of the Constitution supports the asserted interest. ... We have found no other authority supporting the proposition that a grandparent, by virtue of genetic link alone, enjoys a fundamental liberty interest in the adoption of her grandchildren. The mere novelty of the claim is reason enough to doubt that substantive due process sustains it. See Reno v. Flores, 507 U.S. at 301, 113 S.Ct. at 1447; see also Michael H. v. Gerald D., 491 U.S. at 125, 109 S.Ct. at 2343 (noting that the party claiming a fundamental liberty interest has the burden of establishing it).”
1 later decision quote this exact passage · from the dissent“What this case is really about is creating a new family unit where none existed before. That is, the asserted interest is one in a potential, still undeveloped familial relationship with prospective adopted children. In every material re spect except one, this asserted interest is identical to the interest every prospective adoptive parent has in the child he wishes to adopt, and whatever claim a prospective adoptive parent may have to a child, we are .certain that it does not rise to the level of a fundamental liberty interest.”
1 later decision quote this exact passage · from the dissent“Also, we note that grandparents sometimes may be unsuitable adoptive parents precisely because of their blood relationship, especially in cases of abuse such as this in which there may be a well founded fear that the grandparents will be unable to protect the children from future parental contact and abuse.”
1 later decision quote this exact passage · from the dissent
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.