Middendorf v. Middendorf’s Empirical Analysis
1998
Citation profile
239 state decisions
How this case has been cited
Cited by 239 later decisions — most recently March 2026 · most notably 160 Ohio App. 3d 209 - Maloney v. Maloney (2005), 168 Ohio App. 3d 59 - Ostmann v. Ostmann (2006)
239 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 · Holcomb v. Holcomb · Berish v. Berish · Provident Bank v. Wood · Martin v. Martin
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 239 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he plain language of R.C. 3105.17 [1](A)(3)(a)(iii) unambiguously mandates that when either spouse makes a labor, money, or in-kind contribution that causes an increase in the value of separate property, that increase in value is deemed marital property.”
11 later decisions quote this exact passagee.g. Wright v. Cramer · Dach v. Homewood“all income and appreciation on separate property, due to the labor, monetary, or in-kind contribution of either or both of the spouses that occurred during the marriage.”
11 later decisions quote this exact passage“If there is some competent, credible evidence to support the trial court's decision, there is no abuse of discretion.”
10 later decisions 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.