98 Ark. App. 355 - Harmon v. Wells’s Empirical Analysis
2007
Citation profile
13 state decisions
How this case has been cited
Cited by 13 later decisions — most recently April 2021
13 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 75 Ark. App. 390 - Word v. Remick · 82 Ark. App. 47 - Cole v. Cole · Norwood v. Robinson · Freshour v. West · 85 Ark. App. 481 - Sheppard v. Speir
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 13 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“Harmon concedes that the [paternity] order was titled "Temporary Order" but points out that unlike the order analyzed in Speir, this order did not set a final hearing date and ended with the words, "this Court retains jurisdiction of this case for such further orders as may be appropriate for the enforcement of this Temporary Order and for all matters relating to custody, visitation and support of the minor child." She argues that "these are not the words of a temporary order." She also notes that "ten months later, a custody hearing [was] held." .... Contrary to Harmon's assertion otherwise, the law does not prohibit a trial court from entering a temporary order of visitation in favor of the father at the same time that he is found to be the father and reserving the issue of custody for a later time. Speir , 85 Ark. App. at 490, 157 S.W.3d at 589. Therefore, the resolution of the issue before us rests entirely on whether the visitation order was permanent or temporary. If it was permanent, the trial court should have followed Norwood and required a change of circumstances. If it was temporary, the trial court should have followed Speir and should have concluded that there was no need for the father to prove changed circumstances. Although the order did not set a future date for a custody hearing, we conclude that the order was temporary in nature because it did not resolve the issue of custody. As such, the trial court was correct in not requiring a showing of changed circum”
1 later decision quote this exact passagee.g. Rivers v. DeBoer“this Court retains jurisdiction of this case for such further orders as may be appropriate for the enforcement of this Temporary Order and for all matters relating to custody, visitation and support of the minor child.”
1 later decision quote this exact passagee.g. Rivers v. DeBoer“but points out that unlike the order analyzed in Speir, this order did not set a final hearing date and ended with the words,”
1 later decision quote this exact passagee.g. Rivers v. DeBoer
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.