In Re TE’s Empirical Analysis
1990
Citation profile
86 state decisions
How this case has been cited
Cited by 86 later decisions — most recently July 2025 · most notably Billington v. Billington (1991), Beizer v. Goepfert (1992)
86 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 Santosky v. Kramer · In Re MB · In re M. B. · Ordinetz v. Springfield Family Center, Inc. · Board of Medical Practice v. Perry-Hooker
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 86 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“If a parent is able ... to show by a preponderance of the evidence that there has been a substantial change in circumstances and that the best interests of the child require an amendment, modification or vacation of a termination order, the State no longer can maintain the claim that clear and convincing evidence exists to justify the severance of parental rights.”
1 later decision quote this exact passagee.g. In re A.W.“It is settled law that a state's initial burden of proof in seeking to terminate residual parental rights is by clear and convincing evidence.”
1 later decision quote this exact passagee.g. In Re AW
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.