Masters v. Masters’s Empirical Analysis

1994

Citation profile

237

cited by 237 later decisions

states following

February 2026

most recently cited

237 state decisions

How this case has been cited

Cited by 237 later decisions — most recently February 2026 · most notably 110 Ohio App. 3d 615 - Donovan v. Donovan (1996), 156 Ohio App. 3d 26 - Haas v. Bauer (2004)

237 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 Miller v. Miller

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 237 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

“{¶8} “The court shall not modify a prior decree allocating parental rights and responsibilities for the care of children unless it finds, based on facts that have arisen since the prior decree * * * that a change has occurred in the circumstances of the child, [or] the child’s residential parent * * *, and that the modification is necessary to serve the best interest of the child.””
7 later decisions quote this exact passage
e.g. 146 Ohio App. 3d 579 - Saal v. Saal · John A.L. v. Sheri B., Unpublished Decision (10-7-2005)
“connotes more than an error of law or judgment; it implies that the court's attitude is unreasonable, arbitrary, or unconscionable.”
7 later decisions quote this exact passage
e.g. In Matter of Goodwin, 17-08-12 (10-20-2008) · Lempner v. Lempner, Unpublished Decision (8-31-2005)
““The court shall not modify a prior, decree allocating parental rights and responsibilities for the care of children unless it finds, based on facts that have arisen since the prior decree * * * that a change has occurred in the circumstances of the child, [or] his residential parent * * *, and that the modification is necessary to serve the best interest of the child. In applying these standards, the court shall retain the residential parent designated by the prior decree * * *, unless a modification is in the best interest of the child and one of the following applies: U ij; ;¡: * “ * * * The harm likely to be caused by a change of environment is outweighed by the advantages of the change of environment to the child.””
2 later decisions quote this exact passage
e.g. Maxwell v. Maxwell, 07ca0047 (3-24-2008) · 111 Ohio App. 3d 1 - Waggoner v. Waggoner

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.