In re Cunningham’s Empirical Analysis
1979
Citation profile
821 state decisions
How this case has been cited
Cited by 823 later decisions — most recently March 2026 · most notably Miller v. Miller (1988), In re K.H. (2008)
821 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 Stanley v. Illinois · Griswold v. State of Connecticut · Meyer v. State of Nebraska · Skinner v. State of Oklahoma Williamson · May v. Anderson
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 823 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“`it is plain that the natural rights of a parent * * * are always subject to the ultimate welfare of the child, which is the pole star or controlling principle to be observed.'”
51 later decisions quote this exact passage · from the concurrence“when that authority is properly invoked, it is fully proper and constitutional to remove children from their parents' care. [S]uch an extreme disposition is nevertheless expressly sanctioned * * * when it is necessary for the 'welfare' of the child.”
25 later decisions quote this exact passage · from the concurrence“by clear and convincing evidence, that it is in the best interest of the child to grant permanent custody of the child to the agency that filed the motion for permanent custody,”
11 later decisions quote this exact passage · from the concurrence
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.