40 Ohio opinions name it 4 courts 1922–2026 17 in the last five years
The cases below were cited by Ohio 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.
| Case | Followed | Cited |
|---|---|---|
State ex rel. Herman v. Klopfleischgreen2 sentences2022Herman v. Klopfleisch, 72 Ohio St.3d 581, 585 (1995) (“The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.”). 2013Hermann v. Klopfleisch, 72 Ohio St.3d 581, 585 , 651 N.E.2d 995 (1995) (the in pari materia rule may only be used in interpreting statutes where some doubt or ambiguity exists). | 8 | 12 |
Hulsmeyer v. Hospice of Southwest Ohio, Inc. (Slip Opinion)green2 sentences2021Bd. of Commrs., 32 Ohio St.3d 24 , 27–28, 512 N.E.2d 332 (1987); see Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 , 2014- Ohio-5511, 29 N.E.3d 903, ¶ 22 (“ ‘The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.’ ”), quoting State 12 OHIO FIRST DISTRICT COURT OF APPEALS ex rel. 2021Bd. of Commrs., 32 Ohio St.3d 24 , 27–28, 512 N.E.2d 332 (1987); see Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 , 2014- Ohio-5511, 29 N.E.3d 903, ¶ 22 (“ ‘The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.’ ”), quoting State 12 OHIO FIRST DISTRICT COURT OF APPEALS ex rel. | 4 | 5 |
State v. Krutzgreen2 sentences1989As we stated in State v. Krutz (1986), 28 Ohio St. 3d 36, 37-38 , 28 OBR 96, 97, 502 N.E. 2d 210, 211 , certiorari denied (1987), 481 U.S. 1028 , “the in pari materia rule of statutory construction applies ‘only where the statute to be construed is ambiguous or the significance of its terms doubtful.’ ” Since, pursuant to R.C. 2925.03(E)(3), a six-month term of actual incarceration is mandated in this case, under R.C. 2951.02(F)(5) appel lee is simply ineligible for probation. 1989As we stated in State v. Krutz (1986), 28 Ohio St. 3d 36, 37-38 , 28 OBR 96, 97, 502 N.E. 2d 210, 211 , certiorari denied (1987), 481 U.S. 1028 , “the in pari materia rule of statutory construction applies ‘only where the statute to be construed is ambiguous or the significance of its terms doubtful.’ ” Since, pursuant to R.C. 2925.03(E)(3), a six-month term of actual incarceration is mandated in this case, under R.C. 2951.02(F)(5) appel lee is simply ineligible for probation. | 3 | 4 |
Cleveland v. State (Slip Opinion)green2 sentences2024See Cleveland v. State, 2019-Ohio-3820, ¶ 17 (lead opinion), citing State v. Krutz, 28 Ohio St.3d 36, 37-38 (1986), and Ali v. Fed. 2024See Cleveland v. State, 2019-Ohio-3820, ¶ 17 (lead opinion), citing State v. Krutz, 28 Ohio St.3d 36, 37-38 (1986), and Ali v. Fed. | 2 | 2 |
Thomas v. Freemangreen2 sentences2001Herman v. Klopfleisch (1995), 72 Ohio St.3d 581, 585 , 651 N.E.2d 995, 998 (“The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists”); see, also, Thomas v. Freeman (1997), 79 Ohio St.3d 221, 224 , 680 N.E.2d 997, 1000 , where we applied principles of statutory construction in analyzing Rules of Civil Procedure. 2001Herman v. Klopfleisch (1995), 72 Ohio St.3d 581, 585 , 651 N.E.2d 995, 998 (“The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists”); see, also, Thomas v. Freeman (1997), 79 Ohio St.3d 221, 224 , 680 N.E.2d 997, 1000 , where we applied principles of statutory construction in analyzing Rules of Civil Procedure. | 2 | 2 |
In re Application of Duke Energy Ohio, Inc. (Slip Opinion)green2 sentences2025See generally In re Duke Energy Ohio, Inc., 2017-Ohio-5536, ¶ 27 (Under the in pari materia rule of statutory construction, “a court must read all statutes relating to the same general subject matter together to give proper force and effect to each one.”). 2024“Under the in pari materia rule of statutory construction, a court must read all statutes relating to the same general subject matter together to give proper force and effect to each one.” In re Application of Duke Energy Ohio, Inc., 2017-Ohio-5536, ¶ 27 . | 1 | 5 |
State ex rel. Clay v. Cuyahoga Cty. Med. Examiner's Office (Slip Opinion)green2 sentences2022Examiner’s Office, 152 Ohio St.3d 163 , 2017-Ohio-8714 , 94 N.E.3d 498 , ¶ 17 (lead opinion) (the in pari materia rule of statutory construction applies when the wording of a statute is in doubt or ambiguous, i.e., capable of bearing more than one meaning). 2022Examiner’s Office, 152 Ohio St.3d 163 , 2017-Ohio-8714 , 94 N.E.3d 498 , ¶ 17 (lead opinion) (the in pari materia rule of statutory construction applies when the wording of a statute is in doubt or ambiguous, i.e., capable of bearing more than one meaning). | 1 | 3 |
Morgan v. Ohio Adult Parole Authoritygreen2 sentences2021Thus, if the language of the statute is unambiguous, we have “no cause to apply the rules of statutory construction.” Id.; see Jacobson v. Kaforey, 149 Ohio St.3d 398 , 2016-Ohio-8434 , 75 N.E.3d 203, ¶ 8 (“We ‘do not have the authority’ to dig deeper than the plain meaning of an unambiguous statute ‘under the guise of either statutory interpretation or liberal construction.’ ”), quoting Morgan v. Adult Parole Auth., 68 Ohio St.3d 344, 347 , 626 N.E.2d 939 (1994); see also R.C. 1.49 (“If a statute is ambiguous, the court, in determining the intention of the legislature, may consider * * * othe 2021Thus, if the language of the statute is unambiguous, we have “no cause to apply the rules of statutory construction.” Id.; see Jacobson v. Kaforey, 149 Ohio St.3d 398 , 2016-Ohio-8434 , 75 N.E.3d 203, ¶ 8 (“We ‘do not have the authority’ to dig deeper than the plain meaning of an unambiguous statute ‘under the guise of either statutory interpretation or liberal construction.’ ”), quoting Morgan v. Adult Parole Auth., 68 Ohio St.3d 344, 347 , 626 N.E.2d 939 (1994); see also R.C. 1.49 (“If a statute is ambiguous, the court, in determining the intention of the legislature, may consider * * * othe | 1 | 2 |
Jacobson v. Kaforey (Slip Opinion)green2 sentences2021Thus, if the language of the statute is unambiguous, we have “no cause to apply the rules of statutory construction.” Id.; see Jacobson v. Kaforey, 149 Ohio St.3d 398 , 2016-Ohio-8434 , 75 N.E.3d 203, ¶ 8 (“We ‘do not have the authority’ to dig deeper than the plain meaning of an unambiguous statute ‘under the guise of either statutory interpretation or liberal construction.’ ”), quoting Morgan v. Adult Parole Auth., 68 Ohio St.3d 344, 347 , 626 N.E.2d 939 (1994); see also R.C. 1.49 (“If a statute is ambiguous, the court, in determining the intention of the legislature, may consider * * * othe 2021Thus, if the language of the statute is unambiguous, we have “no cause to apply the rules of statutory construction.” Id.; see Jacobson v. Kaforey, 149 Ohio St.3d 398 , 2016-Ohio-8434 , 75 N.E.3d 203, ¶ 8 (“We ‘do not have the authority’ to dig deeper than the plain meaning of an unambiguous statute ‘under the guise of either statutory interpretation or liberal construction.’ ”), quoting Morgan v. Adult Parole Auth., 68 Ohio St.3d 344, 347 , 626 N.E.2d 939 (1994); see also R.C. 1.49 (“If a statute is ambiguous, the court, in determining the intention of the legislature, may consider * * * othe | 1 | 2 |
State v. Coburngreen2 sentences2012See State v. Robinson, 124 Ohio St.3d 76 , 2009-Ohio-5937 , 919 N.E.2d 190, ¶ 31 ; State v. Coburn, 121 Ohio St.3d 310 , 2009-Ohio-834 , 903 N.E.2d 1204 . {¶ 9} Trooper Schack had been issued an operator-access card for the Intoxilyzer 8000 on May 5, 2010. 2012See State v. Robinson, 124 Ohio St.3d 76 , 2009-Ohio-5937 , 919 N.E.2d 190, ¶ 31 ; State v. Coburn, 121 Ohio St.3d 310 , 2009-Ohio-834 , 903 N.E.2d 1204 . {¶ 9} Trooper Schack had been issued an operator-access card for the Intoxilyzer 8000 on May 5, 2010. | 1 | 2 |
In re M.L.green2 sentences2026“It is a cardinal rule of statutory construction that a statute should not be interpreted to yield an absurd result.” In re M.L., 2023-Ohio-3541, ¶ 45 (6th Dist.). 2026“It is a cardinal rule of statutory construction that a statute should not be interpreted to yield an absurd result.” In re M.L., 2023-Ohio-3541, ¶ 45 (6th Dist.). | 1 | 1 |
Baldwin v. Bucklesgreen2 sentences2026“The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.” Baldwin v. Buckles, 2020-Ohio-2759, ¶ 21 (6th Dist.). 2026“The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.” Baldwin v. Buckles, 2020-Ohio-2759, ¶ 21 (6th Dist.). | 1 | 1 |
TWISM Ents., L.L.C. v. State Bd. of Registration for Professional Engineers & Surveyorsgreen1 sentence2023When determining the intention of the legislature with respect to ambiguous statutes, R.C. 1.49(A)-(F) provides that the court may consider, among other things: “[t]he object sought to be attained; [t]he circumstances under which the statute was enacted; [t]he legislative history; [t]he common law or former statutory provisions, including laws upon the same or similar subjects; [t]he consequences of a particular construction; and [t]he administrative construction of the statute.” But see TWISM Enters., LLC v. State Bd. of Registration for Professional Engineers & Surveyors, Slip No. 2021-1440, | 1 | 1 |
Family Medicine Found Inc. v. Brightgreen1 sentence2020Found., Inc. v. Bright, 96 Ohio St.3d 183 , 2002-Ohio-4034, ¶ 8 (stating that "a statute is ambiguous when its language is subject to more than one reasonable interpretation"). {¶ 50} "The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists." State ex rel. | 1 | 1 |
State v. Bryant (Slip Opinion)green1 sentence2020See Bryant, 2020-Ohio-1041 , __ N.E.3d __, at ¶ 26. | 1 | 1 |
Sobieniak v. Chapdelaine, L-08-1173 (12-5-2008)green1 sentence2020Lucas No. L-08-1173, 2008-Ohio-6403, ¶ 4 (neighbor). {¶ 29} We reviewed the matter de novo and find appellee had standing under the in pari materia doctrine to file a petition pursuant to R.C. 2903.214 for her custodial grandson who was a minor. {¶ 30} Appellant’s second assignment of error is not well-taken. | 1 | 1 |
East Ohio Gas Co. v. Public Utilities Commissiongreen1 sentence2018Comm., 39 Ohio St.3d 295, 299 (1988). {¶ 19} Where, as here, a statute refers to other statutes that relate to the same subject matter, the in pari materia rule states that the court must read all statutes relating to the same general subject matter together to give proper force and effect to each one. | 1 | 1 |
State v. Sorrellgreen1 sentence2014See State v. Sorrell, 187 Ohio App.3d 286 , 2010-Ohio-1618 , ¶ 16 (2d Dist.) (“While the object of a support order is clearly the welfare of the dependent child, the child’s claim to any arrearage owed by the offender is secondary to that of the custodial parent or state agency tasked with the responsibility of collecting and distributing the payments made pursuant to the support order fashioned by the court.”). | 1 | 1 |
| McAtee v. Ottawa County Department of Human Servicesgreen | 1 | 1 |
| State v. Robinsongreen | 1 | 1 |
| In re Termination of Employment of Prattgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Fremont Lodge of Loyal Order of Moose
green
2 sentences1991In discussing application of the in pari materia rule, the court stated, at 26-27, 38 O.O. at 509-510 , 84 N.E.2d at 503 : “ ‘The rule in pari materia is, of course, applicable only when the terms of the statute to be construed are ambiguous or its significance is doubtful. 1991In discussing application of the in pari materia rule, the court stated, at 26-27, 38 O.O. at 509-510 , 84 N.E.2d at 503 : “ ‘The rule in pari materia is, of course, applicable only when the terms of the statute to be construed are ambiguous or its significance is doubtful. | 4 | 1984–2003 |
Ali v. Federal Bureau of Prisons
green
2 sentences2024Bur. of Prisons, 552 U.S. 214, 227 (2008). {¶ 64} The majority opinion’s resorting to the in pari materia rule is improper in this case. 2024Bur. of Prisons, 552 U.S. 214, 227 (2008). 21 SUPREME COURT OF OHIO {¶ 64} The majority opinion’s resorting to the in pari materia rule is improper in this case. | 2 | 2024–2024 |
Cater v. City of Cleveland
green
2 sentences2022Gains v. Rossi, 86 Ohio St.3d 620, 622 , 716 N.E.2d 204 (1999), citing Cater v. Cleveland, 83 Ohio St.3d 24, 29 , 697 N.E.2d 610 (1998), but it is applied only “where some doubt or ambiguity exists **503 in the wording of a statute” (emphasis added), *167 State ex rel. 2017Gains v. Rossi , 86 Ohio St.3d 620 , 622, 716 N.E.2d 204 (1999), citing Cater v. Cleveland , 83 Ohio St.3d 24 , 29, 697 N.E.2d 610 (1998), but it is applied only "where some doubt or ambiguity ex *503 ists in the wording of a statute" (emphasis added), *167 State ex rel. | 2 | 2017–2022 |
State v. Pilgrim
green
2 sentences2022Gains v. Rossi, 86 Ohio St.3d 620, 622 , 716 N.E.2d 204 (1999), citing Cater v. Cleveland, 83 Ohio St.3d 24, 29 , 697 N.E.2d 610 (1998), but it is applied only “where some doubt or ambiguity exists **503 in the wording of a statute” (emphasis added), *167 State ex rel. 2017Gains v. Rossi , 86 Ohio St.3d 620 , 622, 716 N.E.2d 204 (1999), citing Cater v. Cleveland , 83 Ohio St.3d 24 , 29, 697 N.E.2d 610 (1998), but it is applied only "where some doubt or ambiguity ex *503 ists in the wording of a statute" (emphasis added), *167 State ex rel. | 2 | 2017–2022 |
State ex rel. Gains v. Rossi
green
2 sentences2022Gains v. Rossi, 86 Ohio St.3d 620, 622 , 716 N.E.2d 204 (1999), citing Cater v. Cleveland, 83 Ohio St.3d 24, 29 , 697 N.E.2d 610 (1998), but it is applied only “where some doubt or ambiguity exists **503 in the wording of a statute” (emphasis added), *167 State ex rel. 2017Gains v. Rossi , 86 Ohio St.3d 620 , 622, 716 N.E.2d 204 (1999), citing Cater v. Cleveland , 83 Ohio St.3d 24 , 29, 697 N.E.2d 610 (1998), but it is applied only "where some doubt or ambiguity ex *503 ists in the wording of a statute" (emphasis added), *167 State ex rel. | 2 | 2017–2022 |
State ex rel. Columbia Reserve Ltd. v. Lorain County Board of Elections
green
2 sentences2009Bd. of Elections, 111 Ohio St.3d 167 , 2006- Ohio-5019, 855 N.E.2d 815 , ¶ 32. {¶ 34} Moreover, by applying the in pari materia rule of statutory construction, the majority implicitly recognizes that R.C. 145.45 is ambiguous. 2009Bd. of Elections, 111 Ohio St.3d 167 , 2006-Ohio-5019 , 855 N.E.2d 815 , ¶ 32. {¶ 34} Moreover, by applying the in pari materia rule of statutory construction, the majority implicitly recognizes that R.C. 145.45 is ambiguous. | 2 | 2008–2009 |
State v. Parker (Slip Opinion)
green
1 sentence2025State v. Parker, 2019-Ohio-3848 , ¶ 31. {¶ 25} Our decision to forgo construing R.C. 9.681 as one overarching statute in combination with all state regulations of tobacco is therefore valid, and, in fact, required by the fundamental limits of judicial power. | 1 | 2025–2025 |
Cleveland Clinic Found. v. Cleveland Bd. of Zoning Appeals (Slip Opinion)
green
2 sentences2022“In reading statutes in pari materia and construing them together, this court must give a reasonable construction that provides the proper effect to each statute.” (Citation omitted.) Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 , 2014-Ohio-5511, ¶ 22 . -16- Case No. 9-21-39 {¶29} Furthermore, “zoning ordinances are to be construed in favor of the property owner because they are in derogation of the common law and deprive the property owner of uses to which the owner would otherwise be entitled.” Cleveland Clinic Found., 141 Ohio St.3d 318 , 2014-Ohio-4809 , at ¶ 34. 2022“In reading statutes in pari materia and construing them together, this court must give a reasonable construction that provides the proper effect to each statute.” (Citation omitted.) Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 , 2014-Ohio-5511, ¶ 22 . -16- Case No. 9-21-39 {¶29} Furthermore, “zoning ordinances are to be construed in favor of the property owner because they are in derogation of the common law and deprive the property owner of uses to which the owner would otherwise be entitled.” Cleveland Clinic Found., 141 Ohio St.3d 318 , 2014-Ohio-4809 , at ¶ 34. | 1 | 2022–2022 |
State ex rel. Celebrezze v. Board of County Commissioners
green
2 sentences2021Bd. of Commrs., 32 Ohio St.3d 24 , 27–28, 512 N.E.2d 332 (1987); see Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 , 2014- Ohio-5511, 29 N.E.3d 903, ¶ 22 (“ ‘The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.’ ”), quoting State 12 OHIO FIRST DISTRICT COURT OF APPEALS ex rel. 2021Bd. of Commrs., 32 Ohio St.3d 24 , 27–28, 512 N.E.2d 332 (1987); see Hulsmeyer v. Hospice of Southwest Ohio, Inc., 142 Ohio St.3d 236 , 2014- Ohio-5511, 29 N.E.3d 903, ¶ 22 (“ ‘The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists.’ ”), quoting State 12 OHIO FIRST DISTRICT COURT OF APPEALS ex rel. | 1 | 2021–2021 |
United Telephone Co. v. Limbach
green
2 sentences2021Co. of Ohio, 71 Ohio St.3d at 372 , 643 N.E.2d 1129 . {¶ 52} In this case, the in pari materia rule of construction does not apply for three reasons. 2021Co. of Ohio, 71 Ohio St.3d at 372 , 643 N.E.2d 1129 . {¶ 52} In this case, the in pari materia rule of construction does not apply for three reasons. | 1 | 2021–2021 |
Family Medicine Foundation, Inc. v. Bright
green
1 sentence2020Found., Inc. v. Bright, 96 Ohio St.3d 183 , 2002-Ohio-4034, ¶ 8 (stating that "a statute is ambiguous when its language is subject to more than one reasonable interpretation"). {¶ 50} "The in pari materia rule of construction may be used in interpreting statutes where some doubt or ambiguity exists." State ex rel. | 1 | 2020–2020 |
Sears v. Weimer
green
2 sentences2017An unambiguous statute is applied, not interpreted." Sears v. Weimer , 143 Ohio St. 312 , 55 N.E.2d 413 (1944), paragraph five of the syllabus. 2017An unambiguous statute is applied, not interpreted." Sears v. Weimer , 143 Ohio St. 312 , 55 N.E.2d 413 (1944), paragraph five of the syllabus. | 1 | 2017–2017 |
| Austin v. Miami Valley Hospital green | 1 | 1995–1995 |
| Mullins Coal Co. v. Director, Office of Workers' Compensation Programs green | 1 | 1989–1989 |
| Morris v. Kaiser Engineers, Inc. green | 1 | 1986–1986 |
| Besnys v. Herman Zohrlaut Leather Co. green | 1 | 1922–1922 |
| Sadowski v. Thomas Furnace Co. green | 1 | 1922–1922 |
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.