Zalenko v. White’s Empirical Analysis

Citation profile

4 state decisions

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

1. “(1) The potential advantages of the proposed move, economic or otherwise, and the likelihood the move would improve substantially the quality of life for the custodial parent and the children and is not the result of a momentary whim on the part of the custodial parent; (2) The integrity of the motive of both the custodial and non-custodial parent in either seeking the move or seeking to prevent it; and (3) The availability of realistic, substitute arrangements which will adequately foster an ongoing relationship between the child and the non-custodial parent.”

   2 later decisions quote this exact passage
   e.g. Beers v. Beers · 1999 Pa. Super. 249 - Thomas v. Thomas

2. “Custody disputes are delicate issues which must be handled on a case by case basis ... It can not be said that every case where the life of a parent is "substantially improved" through relocation, that the life of the child will automatically be "substantially improved." Nor do I believe that to be the intent of Gruber . Such a finding shifts the focus of the inquiry from the child to the parent. As stated, the standard should remain that a substantial improvement is shown for parent and child.”

   1 later decision quote this exact passage · from the dissent
   e.g. 1999 Pa. Super. 307 - Anderson v. McVay

3. “The court must assure itself that the move is not motivated simply by a desire to frustrate the visitation rights of the non-custodial parent or to impede the development between the child and the non-custodial parent.”

   1 later decision quote this exact passage
   e.g. 1999 Pa. Super. 307 - Anderson v. McVay