Cooper standard (District of Columbia) · Go Syfert
← District of Columbia issues

Cooper standard in District of Columbia

13 District of Columbia opinions name it 1 courts 1986–2026 2 in the last five years

The cases below were cited by District of Columbia courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (8)

CaseFollowedCited
Albus v. Albusgreen
dc · 1986 · cited in 5 District of Columbia opinions naming this issue, 1986–2005
2 sentences

2005A trial court may modify such an agreement only upon a showing of “(1) a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper v. Cooper, 472 A.2d 878, 880 (D.C.1984) (citations omitted) (holding that the aforementioned standard is required to modify support payments set in an agreement incorporated but not merged in a divorce decree); see also Foster-Gross v. Puente, 656 A.2d 733, 737 (D.C.1995) (citing id.); Dershowitz, 585 A.2d at 175-76 (applying

2005A trial court may modify such an agreement only upon a showing of “(1) a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper v. Cooper, 472 A.2d 878, 880 (D.C.1984) (citations omitted) (holding that the aforementioned standard is required to modify support payments set in an agreement incorporated but not merged in a divorce decree); see also Foster-Gross v. Puente, 656 A.2d 733, 737 (D.C.1995) (citing id.); Dershowitz, 585 A.2d at 175-76 (applying

45
Cooper v. Coopergreen
dc · 1984 · cited in 6 District of Columbia opinions naming this issue, 1986–2008
2 sentences

2008The Cooper standard allowed modification only upon a showing (1) of "a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper, 472 A.2d at 880 (citations omitted). "[A] change in the parents’ financial circumstances alone cannot provide the basis for modifying a contract between the parties.” Id. at 881 (citation and internal quotation marks omitted).

2008The Cooper standard allowed modification only upon a showing (1) of "a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper, 472 A.2d at 880 (citations omitted). "[A] change in the parents’ financial circumstances alone cannot provide the basis for modifying a contract between the parties.” Id. at 881 (citation and internal quotation marks omitted).

26
Michael D. Tann v. United Statesgreen
dc · 2015 · cited in 2 District of Columbia opinions naming this issue, 2023–2026
2 sentences

2026See Tann, 127 A.3d at 431-32 .

2023Similarly, in Tann v. United States, we upheld a PFCV conviction where Tann complied with his co-conspirator Cooper’s instruction to rob Queen, a member of an opposing crew, as Cooper held another member of Queen’s crew at gunpoint. 127 A.3d at 431-32 .

12
Robinson v. United Statesgreen
dc · 1997 · cited in 1 District of Columbia opinions naming this issue, 2015–2015
1 sentence

2015See (Royce) Robinson v. United States, 697 A.2d 787, 788-89 (D.C.1997).

11
Duffy v. Duffygreen
dc · 2005 · cited in 1 District of Columbia opinions naming this issue, 2008–2008
2 sentences

2008Duffy v. Duffy, 881 A.2d 630, 638 (D.C. 2005). 4 We agree with the trial judge’s determination, on the record before him, that Mazza did not meet the Cooper test for reducing the amount of child support the parties had agreed upon in 1999.

2008Duffy v. Duffy, 881 A.2d 630, 638 (D.C. 2005). 4 We agree with the trial judge’s determination, on the record before him, that Mazza did not meet the Cooper test for reducing the amount of child support the parties had agreed upon in 1999.

11
Dershowitz v. Doctorsgreen
dc · 1991 · cited in 1 District of Columbia opinions naming this issue, 2005–2005
2 sentences

2005A trial court may modify such an agreement only upon a showing of “(1) a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper v. Cooper, 472 A.2d 878, 880 (D.C.1984) (citations omitted) (holding that the aforementioned standard is required to modify support payments set in an agreement incorporated but not merged in a divorce decree); see also Foster-Gross v. Puente, 656 A.2d 733, 737 (D.C.1995) (citing id.); Dershowitz, 585 A.2d at 175-76 (applying

2005A trial court may modify such an agreement only upon a showing of “(1) a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper v. Cooper, 472 A.2d 878, 880 (D.C.1984) (citations omitted) (holding that the aforementioned standard is required to modify support payments set in an agreement incorporated but not merged in a divorce decree); see also Foster-Gross v. Puente, 656 A.2d 733, 737 (D.C.1995) (citing id.); Dershowitz, 585 A.2d at 175-76 (applying

11
Foster-Gross v. Puentegreen
dc · 1995 · cited in 1 District of Columbia opinions naming this issue, 2005–2005
2 sentences

2005A trial court may modify such an agreement only upon a showing of “(1) a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper v. Cooper, 472 A.2d 878, 880 (D.C.1984) (citations omitted) (holding that the aforementioned standard is required to modify support payments set in an agreement incorporated but not merged in a divorce decree); see also Foster-Gross v. Puente, 656 A.2d 733, 737 (D.C.1995) (citing id.); Dershowitz, 585 A.2d at 175-76 (applying

2005A trial court may modify such an agreement only upon a showing of “(1) a change in circumstances which was unforeseen at the time the agreement was entered and (2) that the change is both substantial and material to the welfare and best interests of the children.” Cooper v. Cooper, 472 A.2d 878, 880 (D.C.1984) (citations omitted) (holding that the aforementioned standard is required to modify support payments set in an agreement incorporated but not merged in a divorce decree); see also Foster-Gross v. Puente, 656 A.2d 733, 737 (D.C.1995) (citing id.); Dershowitz, 585 A.2d at 175-76 (applying

11
Thacker v. United Statesgreen
dc · 1991 · cited in 1 District of Columbia opinions naming this issue, 1996–1996
1 sentence

1996We need not consider Cooper’s challenge to this part of the instructions, even assuming for the sake of argument that the issue is properly before us. 14 The murder charge against Cooper went to the jury on alternative theories, under the court’s meticulous instructions, and the verdict form shows that the jury found Cooper guilty on each one separately, first as an aider and abettor and then on the “conspiracy theory.” We note, however, that the court imposed on Cooper two separate sentences for murder. 15 “When there is only one killing, the defendant may not be convicted of more than one mu

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in District of Columbia. Read the followed side critically anyway.

Also cited on this issue (3)

CaseCitedYears
Gatlin v. United States green
dc · 2007
2 sentences

2015Gatlin v. United States, 925 A.2d 594 (D.C.2007) provides a useful framework for analyzing Cooper’s claim.

2015In Gatlin, the defendant, who was incarcerated at the time of the murder of a government witness by his coconspirator, challenged the admissibility of the murdered witness’s grand jury testimony under the forfeiture-by-wrongdoing doctrine. 45 We held that “[ijt'Was reasonably foreseeable that intimidation of and threats to witnesses could result in the murder of a witness.” Id. at 600 .

12015–2015
Brown v. United States green
dc · 2005
1 sentence

2006We note that "when the witness does not make ... a blanket claim, there is usually no need for the court to follow a question-by-question procedure (although the court, of course, may do so if it is appropriate for some other reason).” Brown, 864 A.2d at 1004 . .

12006–2006
Lanahan v. Nevius green
dc · 1974
2 sentences

2005“However, a change in the parents’ financial circumstances alone ‘cannot provide the basis for modifying a contract between the parties.’” Cooper, 472 A.2d at 881 (quoting Lanahan, 317 A.2d at 524 ).

2005“However, a change in the parents’ financial circumstances alone ‘cannot provide the basis for modifying a contract between the parties.’” Cooper, 472 A.2d at 881 (quoting Lanahan, 317 A.2d at 524 ).

12005–2005

Statutes the citing opinions construe

DC § D.C. Code § 16-916 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 21 (1899–2025) TX 18 (1970–2025) FL 17 (1978–2025) GA 14 (1995–2025) DC 13 (1986–2026) NJ 10 (1985–2026) PA 8 (1986–2021) IN 8 (1992–2018) IL 7 (1984–2024) MI 6 (1995–2019) WI 5 (1980–2022) MO 5 (2004–2023) DE 4 (2021–2026) OH 4 (1993–2007) NC 3 (1982–2006) KS 3 (2006–2017) MT 3 (1988–2010) OK 3 (1991–1998) NV 3 (2018–2018) NY 3 (1983–2016) MD 3 (2014–2021) MS 2 (1877–2018) WA 2 (1981–2017) TN 2 (2008–2010) AL 2 (1994–2008) LA 2 (1968–2010) SC 2 (2000–2010) IA 2 (1989–2018) WY 2 (2008–2018) NM 2 (1997–2011)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check