67 N.C. App. 16 - In Re Phifer’s Empirical Analysis
1984
Citation profile
22 state decisions
How this case has been cited
Cited by 22 later decisions — most recently December 2016
22 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 In Re Clark · In re J. M. · In Re JM · 50 N.C. App. 332 - In Re Biggers · 25 Ariz. App. 380 - In Re the Appeal in Pima County, Juvenile Action No. S-111
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“At the very most, these findings present a threat that at some time in the future respondent might not be able to provide adequate care and supervision, if she fails to change her habits and lifestyle. ... A finding of fact that a parent abuses alcohol, without proof of adverse impact upon the child, is not a sufficient basis for an adjudication of termination of parental rights for neglect.”
1 later decision quote this exact passage“[a] finding of fact that a parentabuses alcohol, without proof of adverse impact upon the child, is not a sufficient basis for an adjudication of termination of parental rights for neglect.”
1 later decision quote this exact passagee.g. IN THE MATTER OF DDH“[i]t is also significant that petitioner is unable to cite any decision from our courts supporting the contention that risk of harm is sufficient grounds for termination.”
1 later decision quote this exact passagee.g. IN THE MATTER OF DDH
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.