76 Ohio App. 3d 482 - Thomas v. Thomas’s Empirical Analysis
1991
Citation profile
29 state decisions
How this case has been cited
Cited by 29 later decisions — most recently September 2023 · most notably 98 Ohio App. 3d 748 - Moell v. Moell (1994), Morford v. Morford (2018)
29 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 Blakemore v. Blakemore · Wolfe v. Wolfe · 11 Ohio App. 3d 279 - Taylor v. Taylor · 55 Ohio App. 3d 117 - Bussey v. Bussey · 61 Ohio App. 3d 269 - 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 29 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'[Spousal support] is provided for the needed support of the ex-spouse and, if the ex-spouse is living with another person to the extent that the other person provides support or is supported, then the underlying need for [spousal support] is reduced or does not exist. Therefore, cohabitation, in the legal sense, implies that some sort of monetary support is being provided by the new partner or for the new partner. Without a showing of support, merely living together is insufficient to permit a termination of [spousal support].'”
6 later decisions quote this exact passage“(7/14/04 Divorce Decree, pp. 2-3.) {¶ 90} Ohio courts have held that, under proper circumstances, cohabitation can constitute grounds for the termination of spousal support. Wolfe v. Wolfe (1976), 46 Ohio St.2d 399 , 75 O.O.2d 474 , 350 N.E.2d 413 ; Taylor v. Taylor (1983), 11 Ohio App.3d 279 , 11 OBR 459, 465 N.E.2d 476 ; Miller v. Miller (1989), 61 Ohio App.3d 269 , 572 N.E.2d 742 . {¶ 91}”
1 later decision quote this exact passage“[I]solated acts of sexual intercourse, unaccompanied by other aspects of living together, would not constitute cohabitation, but that, on the other hand, cohabitation can be based entirely upon acts of living together without sexual relations. Cohabitation requires some regularity of functions as would a husband and wife, either sexually or otherwise.”
1 later decision quote this exact passage
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.