pari materia rule (Ohio) · Go Syfert
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pari materia rule in Ohio

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.

Followed or applied (21)

CaseFollowedCited
State ex rel. Herman v. Klopfleischgreen
ohio · 1995 · cited in 12 Ohio opinions naming this issue, 2001–2023
2 sentences

2022Herman 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).

812
Hulsmeyer v. Hospice of Southwest Ohio, Inc. (Slip Opinion)green
ohio · 2014 · cited in 5 Ohio opinions naming this issue, 2018–2024
2 sentences

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.

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.

45
State v. Krutzgreen
ohio · 1986 · cited in 4 Ohio opinions naming this issue, 1989–2024
2 sentences

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.

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.

34
Cleveland v. State (Slip Opinion)green
ohio · 2019 · cited in 2 Ohio opinions naming this issue, 2024–2024
2 sentences

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.

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.

22
Thomas v. Freemangreen
ohio · 1997 · cited in 2 Ohio opinions naming this issue, 2001–2001
2 sentences

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.

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.

22
In re Application of Duke Energy Ohio, Inc. (Slip Opinion)green
ohio · 2017 · cited in 5 Ohio opinions naming this issue, 2018–2025
2 sentences

2025See 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 .

15
State ex rel. Clay v. Cuyahoga Cty. Med. Examiner's Office (Slip Opinion)green
ohio · 2017 · cited in 3 Ohio opinions naming this issue, 2018–2022
2 sentences

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).

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).

13
Morgan v. Ohio Adult Parole Authoritygreen
ohio · 1994 · cited in 2 Ohio opinions naming this issue, 2017–2021
2 sentences

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

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

12
Jacobson v. Kaforey (Slip Opinion)green
ohio · 2016 · cited in 2 Ohio opinions naming this issue, 2017–2021
2 sentences

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

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

12
State v. Coburngreen
ohio · 2009 · cited in 2 Ohio opinions naming this issue, 2009–2012
2 sentences

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.

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.

12
In re M.L.green
ohioctapp · 2023 · cited in 1 Ohio opinions naming this issue, 2026–2026
2 sentences

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.).

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.).

11
Baldwin v. Bucklesgreen
ohioctapp · 2020 · cited in 1 Ohio opinions naming this issue, 2026–2026
2 sentences

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.).

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.).

11
TWISM Ents., L.L.C. v. State Bd. of Registration for Professional Engineers & Surveyorsgreen
ohio · 2022 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023When 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,

11
Family Medicine Found Inc. v. Brightgreen
ohio · 2002 · cited in 1 Ohio opinions naming this issue, 2020–2020
1 sentence

2020Found., 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.

11
State v. Bryant (Slip Opinion)green
· 2020 · cited in 1 Ohio opinions naming this issue, 2020–2020
1 sentence

2020See Bryant, 2020-Ohio-1041 , __ N.E.3d __, at ¶ 26.

11
Sobieniak v. Chapdelaine, L-08-1173 (12-5-2008)green
ohioctapp · 2008 · cited in 1 Ohio opinions naming this issue, 2020–2020
1 sentence

2020Lucas 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.

11
East Ohio Gas Co. v. Public Utilities Commissiongreen
ohio · 1988 · cited in 1 Ohio opinions naming this issue, 2018–2018
1 sentence

2018Comm., 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.

11
State v. Sorrellgreen
ohioctapp · 2010 · cited in 1 Ohio opinions naming this issue, 2014–2014
1 sentence

2014See 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.”).

11
McAtee v. Ottawa County Department of Human Servicesgreen
ohioctapp · 1996 · cited in 1 Ohio opinions naming this issue, 2014–2014
11
State v. Robinsongreen
ohio · 2009 · cited in 1 Ohio opinions naming this issue, 2012–2012
11
In re Termination of Employment of Prattgreen
ohio · 1974 · cited in 1 Ohio opinions naming this issue, 1978–1978
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (17)

CaseCitedYears
State v. Fremont Lodge of Loyal Order of Moose green
· 1949
2 sentences

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.

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.

41984–2003
Ali v. Federal Bureau of Prisons green
scotus · 2008
2 sentences

2024Bur. 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.

22024–2024
Cater v. City of Cleveland green
ohio · 1998
2 sentences

2022Gains 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.

22017–2022
State v. Pilgrim green
ohio · 1999
2 sentences

2022Gains 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.

22017–2022
State ex rel. Gains v. Rossi green
ohio · 1999
2 sentences

2022Gains 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.

22017–2022
State ex rel. Columbia Reserve Ltd. v. Lorain County Board of Elections green
ohio · 2006
2 sentences

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.

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.

22008–2009
State v. Parker (Slip Opinion) green
ohio · 2019
1 sentence

2025State 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.

12025–2025
Cleveland Clinic Found. v. Cleveland Bd. of Zoning Appeals (Slip Opinion) green
ohio · 2014
2 sentences

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.

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.

12022–2022
State ex rel. Celebrezze v. Board of County Commissioners green
ohio · 1987
2 sentences

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.

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.

12021–2021
United Telephone Co. v. Limbach green
ohio · 1994
2 sentences

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.

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.

12021–2021
Family Medicine Foundation, Inc. v. Bright green
ohio · 2002
1 sentence

2020Found., 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.

12020–2020
Sears v. Weimer green
ohio · 1944
2 sentences

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.

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.

12017–2017
Austin v. Miami Valley Hospital green
ohioctapp · 1984
11995–1995
Mullins Coal Co. v. Director, Office of Workers' Compensation Programs green
scotus · 1987
11989–1989
Morris v. Kaiser Engineers, Inc. green
ohio · 1984
11986–1986
Besnys v. Herman Zohrlaut Leather Co. green
wis · 1914
11922–1922
Sadowski v. Thomas Furnace Co. green
· 1914
11922–1922

Where else courts name it

TX 109 (1952–2026) IL 98 (1979–2026) MI 77 (1988–2026) FL 43 (2005–2025) OH 40 (1922–2026) MN 11 (1994–2017) MS 10 (1989–2023) AZ 10 (1988–2025) WV 8 (1986–2024) MO 8 (2016–2022) PA 8 (2010–2023) KY 6 (1920–2019) NJ 5 (1975–2022) HI 4 (2006–2025) MD 4 (1986–2025) IA 4 (1995–2007) CA 3 (1963–1988) WI 3 (1987–2020) CO 3 (2009–2013) IN 3 (1956–2018) VA 3 (2023–2025) NV 2 (2022–2022) GA 2 (2015–2016) ID 2 (2014–2023) NC 2 (1925–2007) AL 2 (1987–2026) TN 2 (2015–2018) CT 2 (1983–1999)

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.

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