Prchal v. Prchal’s Empirical Analysis
2011
Citation profile
43 state decisions
How this case has been cited
Cited by 43 later decisions — most recently February 2026 · most notably Sall v. Sall (2011), Wolt v. Wolt (2011)
43 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 Aus v. Carter · Lapp v. Lapp · Reinecke v. Griffeth · Flattum-Riemers v. Flattum-Riemers · DUFNER v. Trottier
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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“'A party seeking a contempt sanction under N.D.C.C. ch. 27-10 must clearly and satisfactorily prove the alleged contempt was committed.'”
7 later decisions quote this exact passage““To modify parenting time, ‘a material change of circumstances occurs when important new facts arise that were unknown at the time of the initial [parenting time] order.’ Dufner, 2010 ND 31, ¶ 7 , 778 N.W.2d 586 (citing Helfenstein [v. Schutt ], 2007 ND 106, ¶ 18 , 735 N.W.2d 410 ). See also Young v. Young, 2008 ND 55, ¶¶ 14-15 , 746 N.W.2d 153 (mother’s scheduling problems, together with the child’s recent behavior, constituted sufficient material change in circumstances) (citing Ibach v. Zacher, 2006 ND 244, ¶ 10 , 724 N.W.2d 165 (mother’s out-of-town move and father’s illness a sufficient material change); Simburger v. Simburger, 2005 ND 139, ¶ 18 , 701 N.W.2d 880 (mother’s agreement for unsupervised visitation with father followed by mother’s unwillingness to allow unsupervised visitation constituted a material change); Reinecke v. Griffeth, 533 N.W.2d 695, 698-99 (N.D.1995) (son’s attention deficit disorder diagnosis coupled with the visitation’s interference with son’s school work is an implied material change)). “Our decisions also provide the standard to determine whether a modification is in a child’s ‘best interests’ based on the factual circumstances of each case. See Dufner, 2010 ND 31, ¶¶ 9-10 , 778 N.W.2d 586 (affirming visitation modification where court found children were frustrated with incessant bickering between parents and stating ‘[c]ontinually exposing a child to adult conflict is not in that child’s best interests’); Reinecke, 533 N.W.2d at 698-99 (hol”
2 later decisions quote this exact passage“the court, upon request of the other parent, shall grant such rights of parenting time as will enable the child to maintain a parent-child relationship that will be beneficial to the child, unless the court finds, after a hearing, that such rights of parenting time are likely to endanger the child's physical or emotional health.”
1 later decision quote this exact passagee.g. Rath v. Rath
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.