60 Ohio App. 3d 136 - In Re Brown’s Empirical Analysis
1989
Citation profile
23 state decisions
How this case has been cited
Cited by 23 later decisions — most recently April 2025
23 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 70 Ohio App. 2d 117 - In Re Bibb
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[N]othing prohibits a court from basing a permanent custody decision upon a parent's past history with a children services agency. In fact, courts have recognized that a parent's past history is one of the best predicators of future behavior.' " In re M.W., 10th Dist. No. 19AP-769, 2020-Ohio-5199, ¶ 48 , quoting In re West, 4th Dist. No. 05CA4, 2005-Ohio-2977, ¶ 28 . In re M.W. expanded at length on this concept: [A] parent's "past parenting history and her ability to comply with prior reunification plans regarding her other children [are] relevant considerations in the juvenile court's dispositional determination to commit [mother's current child] to the permanent custody of the Department.”
5 later decisions quote this exact passage · from the majority
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.