Nielson v. Thompson’s Empirical Analysis
1999
Citation profile
1 district · 7 state decisions
How this case has been cited
Cited by 8 later decisions — most recently September 2024
1 district · 7 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 United States v. City of New Britain · California v. ARC America Corp. · Smithson v. United States · In Re the Marriage of Brown · In Re Questions Submitted by United States Dist. Ct.
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 8 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““In Nielsori v. Thompson, 982 P.2d 709 (Wyo.1999), we considered whether a judgment creditor was entitled to intervene in the parties’ divorce action. We stated: “ While this Court has said that third parties claiming rights in property that is subject to a property settlement may intervene or be joined, we were not addressing the rights of .a judgment creditor. Merritt v. Merritt, 586 P.2d 550, 554 (Wyo.1978). Some states, notably those with community property laws, permit creditors to intervene in divorce actions as a matter of course.. Elms v. Elms, 4 Cal.2d 681 , 52 P.2d 223, 224 (1935); Malcolm v. Malcolm, 75 N.M. .566, 408 P.2d 143, 144 (1965); Fletcher v. National Bank of Commerce, 825 S.W.2d 176, 179 (Tex.App.lp92); Boyle v. Boyle, 194 W.Va. 124 , 459 S.E,2d 401, 404 (1995). On the other hand, several states bar creditors from intervening in divorce cases. Eberly v. Eberly, 489 A.2d 433, 446 (Del.Supr.1985); Poteat v. Poteat, 632 S.W.2d 511, 512 (Mo.App.1982); Foundation Sav. & Loan Co. v. Rosenbaum, 113 Ohio App. 501 , 171 N.E.2d 359, 360 (1960); Bailey v. Bailey, 312 S.C: 454,- 441 S.E.2d 325, 327 (1994). We are convinced that the authority of the court in a divorce action to divide property is simply ancillary to its authority to dissolve the marriage. The primary subject of a divorce action is the dissolution of the marriage, and the only proper parties to such an action are the spouses seeking to be divorced. In re Marriage of Soriano, 44 Wash.App. 420 , 722 P.2d”
3 later decisions quote this exact passagee.g. Davis v. Davis · Olsen v. Olsen““[ujpon timely application anyone may be permitted to intervene in an action: (1) when a statute confers a conditional right to intervene; or (2) when an applicant’s claim or defense and the main action, have a question of law or fact in common.””
1 later decision quote this exact passagee.g. Davis v. Davis
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.