Mathews test (Ohio) · Go Syfert
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Mathews test in Ohio

20 Ohio opinions name it 2 courts 1986–2025 3 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 (9)

CaseFollowedCited
Mathews v. Eldridgegreen
scotus · 1976 · cited in 11 Ohio opinions naming this issue, 1987–2020
2 sentences

2019The three factors to be considered are: "(1) the private interest that will be affected by the official action; (2) the risk of an erroneous deprivation of such interest through the procedures used, and probable value, if any, of additional procedural safeguards; and (3) the Government's interest, including the fiscal and administrative burdens that the additional or substitute procedures would entail." Mathews v. Eldridge, 424 U.S. 319, 334 , 96 S.Ct. 893 (1976). {¶ 18} Upon consideration of the Mathews factors, this court does not find that the record contains evidence establishing plain err

2019The three factors to be considered are: "(1) the private interest that will be affected by the official action; (2) the risk of an erroneous deprivation of such interest through the procedures used, and probable value, if any, of additional procedural safeguards; and (3) the Government's interest, including the fiscal and administrative burdens that the additional or substitute procedures would entail." Mathews v. Eldridge, 424 U.S. 319, 334 , 96 S.Ct. 893 (1976). {¶ 18} Upon consideration of the Mathews factors, this court does not find that the record contains evidence establishing plain err

211
In re Hayesred
ohio · 1997 · cited in 2 Ohio opinions naming this issue, 2020–2022
2 sentences

2022"The three factors considered in a Mathews analysis are (1) the private interest affected, (2) the risk of erroneous deprivation and the probable value of additional safeguards, and (3) the governmental burden of additional procedural requirements." In re Sprague, 113 Ohio App.3d 274, 276 (12th Dist.1996), citing Mathews at 335 . {¶ 12} As to the first Mathews factor—that is, the private interest affected—"[i]t is well recognized that the right to raise a child is an 'essential' and 'basic' civil right." In re Hayes, 79 Ohio St.3d 46, 48 (1997), citing In re Murray, 52 Ohio St.3d 155, 157 (199

2022"The three factors considered in a Mathews analysis are (1) the private interest affected, (2) the risk of erroneous deprivation and the probable value of additional safeguards, and (3) the governmental burden of additional procedural requirements." In re Sprague, 113 Ohio App.3d 274, 276 (12th Dist.1996), citing Mathews at 335 . {¶ 12} As to the first Mathews factor—that is, the private interest affected—"[i]t is well recognized that the right to raise a child is an 'essential' and 'basic' civil right." In re Hayes, 79 Ohio St.3d 46, 48 (1997), citing In re Murray, 52 Ohio St.3d 155, 157 (199

22
In Re Spraguegreen
ohioctapp · 1996 · cited in 2 Ohio opinions naming this issue, 2022–2024
2 sentences

2024The Mathews test requires the court to consider three factors: “[1] the private interest that will be affected by the official action; [2] the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and [3] the Government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.” Id. at 335 ; Sears; L.C. at ¶ 9; M.M. at ¶ 44; Sprague at 276 .

2024The Mathews test requires the court to consider three factors: “[1] the private interest that will be affected by the official action; [2] the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or substitute procedural safeguards; and [3] the Government’s interest, including the function involved and the fiscal and administrative burdens that the additional or substitute procedural requirement would entail.” Id. at 335 ; Sears; L.C. at ¶ 9; M.M. at ¶ 44; Sprague at 276 .

12
In re Murraygreen
ohio · 1990 · cited in 2 Ohio opinions naming this issue, 2014–2022
2 sentences

2022"The three factors considered in a Mathews analysis are (1) the private interest affected, (2) the risk of erroneous deprivation and the probable value of additional safeguards, and (3) the governmental burden of additional procedural requirements." In re Sprague, 113 Ohio App.3d 274, 276 (12th Dist.1996), citing Mathews at 335 . {¶ 12} As to the first Mathews factor—that is, the private interest affected—"[i]t is well recognized that the right to raise a child is an 'essential' and 'basic' civil right." In re Hayes, 79 Ohio St.3d 46, 48 (1997), citing In re Murray, 52 Ohio St.3d 155, 157 (199

2022"The three factors considered in a Mathews analysis are (1) the private interest affected, (2) the risk of erroneous deprivation and the probable value of additional safeguards, and (3) the governmental burden of additional procedural requirements." In re Sprague, 113 Ohio App.3d 274, 276 (12th Dist.1996), citing Mathews at 335 . {¶ 12} As to the first Mathews factor—that is, the private interest affected—"[i]t is well recognized that the right to raise a child is an 'essential' and 'basic' civil right." In re Hayes, 79 Ohio St.3d 46, 48 (1997), citing In re Murray, 52 Ohio St.3d 155, 157 (199

12
In re B.M.green
ohioctapp · 2023 · cited in 1 Ohio opinions naming this issue, 2025–2025
2 sentences

2025That is, when considering and weighing this factor along with the other Mathews factors, we find Father's due process rights were adequately protected. {¶ 67} Father's first assignment of error is therefore overruled. {¶ 68} Father's Second Assignment of Error: {¶ 69} FATHER'S RIGHT TO EFFECTIVE ASSISTANCE OF COUNSEL WAS DENIED IN THE PERMANENT CUSTODY HEARINGS. {¶ 70} In Father's remaining assignment of error, he argues his counsel provided ineffective assistance by failing to ensure Father was able to present testimony at trial; failing to cross-examine Strong on the appropriateness of Fathe

2025That is, when considering and weighing this factor along with the other Mathews factors, we find Father's due process rights were adequately protected. {¶ 67} Father's first assignment of error is therefore overruled. {¶ 68} Father's Second Assignment of Error: {¶ 69} FATHER'S RIGHT TO EFFECTIVE ASSISTANCE OF COUNSEL WAS DENIED IN THE PERMANENT CUSTODY HEARINGS. {¶ 70} In Father's remaining assignment of error, he argues his counsel provided ineffective assistance by failing to ensure Father was able to present testimony at trial; failing to cross-examine Strong on the appropriateness of Fathe

11
In re B.J.green
ohioctapp · 2016 · cited in 1 Ohio opinions naming this issue, 2025–2025
2 sentences

2025That is, when considering and weighing this factor along with the other Mathews factors, we find Father's due process rights were adequately protected. {¶ 67} Father's first assignment of error is therefore overruled. {¶ 68} Father's Second Assignment of Error: {¶ 69} FATHER'S RIGHT TO EFFECTIVE ASSISTANCE OF COUNSEL WAS DENIED IN THE PERMANENT CUSTODY HEARINGS. {¶ 70} In Father's remaining assignment of error, he argues his counsel provided ineffective assistance by failing to ensure Father was able to present testimony at trial; failing to cross-examine Strong on the appropriateness of Fathe

2025That is, when considering and weighing this factor along with the other Mathews factors, we find Father's due process rights were adequately protected. {¶ 67} Father's first assignment of error is therefore overruled. {¶ 68} Father's Second Assignment of Error: {¶ 69} FATHER'S RIGHT TO EFFECTIVE ASSISTANCE OF COUNSEL WAS DENIED IN THE PERMANENT CUSTODY HEARINGS. {¶ 70} In Father's remaining assignment of error, he argues his counsel provided ineffective assistance by failing to ensure Father was able to present testimony at trial; failing to cross-examine Strong on the appropriateness of Fathe

11
In Re P.J., 2008-A-0047 (1-16-2009)green
ohioctapp · 2009 · cited in 1 Ohio opinions naming this issue, 2022–2022
1 sentence

2022Ashtabula Nos. 2008-A-0047 and 2008-A-0053, 2009-Ohio-182, ¶ 46-54 (applying Mathews factors to determine if court -4- Preble CA2021-09-008 denied incarcerated parent due process when court denied parent's request to attend and present evidence by telephone).

11
In the Matter of Mercedes, Unpublished Decision (7-25-2005)green
ohioctapp · 2005 · cited in 1 Ohio opinions naming this issue, 2020–2020
2 sentences

2020The Supreme Court of the United States, in Mathews v. Eldridge, 424 U.S. 319, 334 (1976), set forth the following legal standard utilizing three criteria to evaluate due process rights: [1][T]he private interest that will be affected by the official action; [2] the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or 7 substitute procedural safeguards; and [3] the Government’s interest, including the function involved the fiscal and administrative burdens that the additional or substitute procedural requirement would en

2020The Supreme Court of the United States, in Mathews v. Eldridge, 424 U.S. 319, 334 (1976), set forth the following legal standard utilizing three criteria to evaluate due process rights: [1][T]he private interest that will be affected by the official action; [2] the risk of an erroneous deprivation of such interest through the procedures used, and the probable value, if any, of additional or 7 substitute procedural safeguards; and [3] the Government’s interest, including the function involved the fiscal and administrative burdens that the additional or substitute procedural requirement would en

11
Sohi v. Ohio State Dental Boardgreen
ohioctapp · 1998 · cited in 1 Ohio opinions naming this issue, 2001–2001
2 sentences

2001Sohi at 422, 720 N.E.2d 187 .

2001Sohi at 422, 720 N.E.2d 187 .

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 (13)

CaseCitedYears
Kutschbach v. Davies green
ohsd · 1995
2 sentences

1999After, applying the Mathews test, the district court concluded that the violation to due process by R.C. 4507.38 was “manifest” and that “the procedures set forth in the statute virtually ensure the erroneous deprivation of * * * property.” Id.

1999After, applying the Mathews test, the district court concluded that the violation to due process by R.C. 4507.38 was “manifest” and that “the procedures set forth in the statute virtually ensure the erroneous deprivation of * * * property.” Id.

31996–1999
City of Maumee v. Gabriel green
ohio · 1988
2 sentences

1996Although we have previously applied the Mathews test in determining that an administrative suspension of a driver’s license does not violate due process when a postsuspension hearing is provided, Gabriel, 35 Ohio St.3d at 62-63 , 518 N.E.2d at 561-562 , the statute at issue here requires an independent application of the Mathews test.

1996Although we have previously applied the Mathews test in determining that an administrative suspension of a driver’s license does not violate due process when a postsuspension hearing is provided, Gabriel, 35 Ohio St.3d at 62-63 , 518 N.E.2d at 561-562 , the statute at issue here requires an independent application of the Mathews test.

21996–1996
MacKey v. Montrym green
scotus · 1979
2 sentences

1996This interest is substantial, in part because the state “will not be able to make a driver whole for any personal inconvenience or economic hardship suffered by reason of any delay in redressing an erroneous suspension through postsuspension review procedures.” Mackey , at 11, 99 S.Ct. at 2617 , 61 L.Ed.2d at 330 .

1996This interest is substantial, in part because the state “will not be able to make a driver whole for any personal inconvenience or economic hardship suffered by reason of any delay in redressing an erroneous suspension through postsuspension review procedures.” Mackey , at 11, 99 S.Ct. at 2617 , 61 L.Ed.2d at 330 .

21996–1996
Strickland v. Washington green
scotus · 1984
2 sentences

2025In determining whether counsel was ineffective in a permanent custody hearing, a reviewing court must apply the two-tier test of Strickland v. Washington, 466 U.S. 668 (1984).

2025In determining whether counsel was ineffective in a permanent custody hearing, a reviewing court must apply the two-tier test of Strickland v. Washington, 466 U.S. 668 (1984).

12025–2025
State v. Unger green
ohio · 1981
2 sentences

2024Sprague at 277 . {¶ 43} In sum, a balancing of the Mathews factors demonstrates the juvenile court did not deprive appellant of her due process rights by denying her counsel’s request for a continuance in order for her to be transported from jail so that she could attend the permanent custody hearing. {¶ 44} We further note that a trial court’s discretion on a motion to continue “is a matter that is entrusted to the broad, sound discretion of the trial judge.” State v. Unger, 67 Ohio St.2d 65 (1981), syllabus.

2024Sprague at 277 . {¶ 43} In sum, a balancing of the Mathews factors demonstrates the juvenile court did not deprive appellant of her due process rights by denying her counsel’s request for a continuance in order for her to be transported from jail so that she could attend the permanent custody hearing. {¶ 44} We further note that a trial court’s discretion on a motion to continue “is a matter that is entrusted to the broad, sound discretion of the trial judge.” State v. Unger, 67 Ohio St.2d 65 (1981), syllabus.

12024–2024
Stanley v. Illinois green
scotus · 1972
2 sentences

2022"The three factors considered in a Mathews analysis are (1) the private interest affected, (2) the risk of erroneous deprivation and the probable value of additional safeguards, and (3) the governmental burden of additional procedural requirements." In re Sprague, 113 Ohio App.3d 274, 276 (12th Dist.1996), citing Mathews at 335 . {¶ 12} As to the first Mathews factor—that is, the private interest affected—"[i]t is well recognized that the right to raise a child is an 'essential' and 'basic' civil right." In re Hayes, 79 Ohio St.3d 46, 48 (1997), citing In re Murray, 52 Ohio St.3d 155, 157 (199

2022"The three factors considered in a Mathews analysis are (1) the private interest affected, (2) the risk of erroneous deprivation and the probable value of additional safeguards, and (3) the governmental burden of additional procedural requirements." In re Sprague, 113 Ohio App.3d 274, 276 (12th Dist.1996), citing Mathews at 335 . {¶ 12} As to the first Mathews factor—that is, the private interest affected—"[i]t is well recognized that the right to raise a child is an 'essential' and 'basic' civil right." In re Hayes, 79 Ohio St.3d 46, 48 (1997), citing In re Murray, 52 Ohio St.3d 155, 157 (199

12022–2022
In Re C.M., Unpublished Decision (8-8-2007) green
ohioctapp · 2007
2 sentences

2020Summit Nos. 23606, 23608, and 23629, 2007-Ohio-3999, ¶ 14 , citing Mathews at 335 .

2020Summit Nos. 23606, 23608, and 23629, 2007-Ohio-3999, ¶ 14 , citing Mathews at 335 .

12020–2020
Snyder v. Massachusetts green
scotus · 1934
2 sentences

2017In Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the Supreme Court set forth a narrower procedural-due-proeess inquiry than the Mathews framework for application in matters of criminal procedure: whether a state rule “ ‘offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.’ ” Id. at 202, quoting Snyder v. Massachusetts, 291 U.S. 97, 105 , 54 S.Ct. 330 , 78 L.Ed. 674 (1934).

2017In Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the Supreme Court set forth a narrower procedural-due-proeess inquiry than the Mathews framework for application in matters of criminal procedure: whether a state rule “ ‘offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.’ ” Id. at 202, quoting Snyder v. Massachusetts, 291 U.S. 97, 105 , 54 S.Ct. 330 , 78 L.Ed. 674 (1934).

12017–2017
Patterson v. New York green
scotus · 1977
2 sentences

2017In Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the Supreme Court set forth a narrower procedural-due-proeess inquiry than the Mathews framework for application in matters of criminal procedure: whether a state rule “ ‘offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.’ ” Id. at 202, quoting Snyder v. Massachusetts, 291 U.S. 97, 105 , 54 S.Ct. 330 , 78 L.Ed. 674 (1934).

2017In Patterson v. New York, 432 U.S. 197 , 97 S.Ct. 2319 , 53 L.Ed.2d 281 (1977), the Supreme Court set forth a narrower procedural-due-proeess inquiry than the Mathews framework for application in matters of criminal procedure: whether a state rule “ ‘offends some principle of justice so rooted in the traditions and conscience of our people as to be ranked as fundamental.’ ” Id. at 202, quoting Snyder v. Massachusetts, 291 U.S. 97, 105 , 54 S.Ct. 330 , 78 L.Ed. 674 (1934).

12017–2017
Nos. 96-5132, 96-5416 green
ca3 · 1997
2 sentences

2006Id., 424 U.S. at 334 , 96 S.Ct. 893 , 47 L.Ed.2d 18 .

2006Id., 424 U.S. at 334 , 96 S.Ct. 893 , 47 L.Ed.2d 18 .

12006–2006
cluster 729996 green
ca10 · 1996
2 sentences

2003Benavidez v. Albuquerque (C.A.10, 1996), 101 F.3d 620 , 625. {¶ 13} Turning now to the Mathews factors, we recognize that an employee has a significant private interest in retaining public employment.

2003Benavidez v. Albuquerque (C.A.10, 1996), 101 F.3d 620 , 625. {¶ 13} Turning now to the Mathews factors, we recognize that an employee has a significant private interest in retaining public employment.

12003–2003
Cleveland Board of Education v. Loudermill green
scotus · 1985
2 sentences

2003Loudermill, 470 U.S. at 532 , 105 S.Ct. 1487 , 84 L.Ed.2d 494 .

2003Loudermill, 470 U.S. at 532 , 105 S.Ct. 1487 , 84 L.Ed.2d 494 .

12003–2003
Oliver v. Kaiser Community Health Foundation green
ohio · 1983
2 sentences

1986Meyers advances a single assignment of error: “The lower court erred in finding that the appellant failed to file a timely medical malpractice action against ap-pellee Mathews.” Oliver v. Kaiser Community Health Found. (1983), 5 Ohio St. 3d 111 , 5 OBR 247, 449 N.E. 2d 438 , syllabus, provides: “Under R.C. 2305.11(A), a cause of action for medical malpractice accrues and the statute of limitations commences to *162 ran when the patient discovers, or, in the exercise of reasonable care and diligence should have discovered, the resulting injury. * * *” We have interpreted Oliver as holding that

1986Meyers advances a single assignment of error: “The lower court erred in finding that the appellant failed to file a timely medical malpractice action against ap-pellee Mathews.” Oliver v. Kaiser Community Health Found. (1983), 5 Ohio St. 3d 111 , 5 OBR 247, 449 N.E. 2d 438 , syllabus, provides: “Under R.C. 2305.11(A), a cause of action for medical malpractice accrues and the statute of limitations commences to *162 ran when the patient discovers, or, in the exercise of reasonable care and diligence should have discovered, the resulting injury. * * *” We have interpreted Oliver as holding that

11986–1986

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2151.414 (7) OH § Ohio Rev. Code § 2151.353 (3) OH § Ohio Rev. Code § 2151.415 (3) OH § Ohio Rev. Code § 4511.19 (3) OH § Ohio Rev. Code § 4511.195 (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

WA 92 (1986–2026) NM 58 (1997–2025) IL 57 (1979–2026) CA 40 (1981–2025) PA 26 (1990–2025) NJ 25 (1990–2026) CT 22 (1996–2025) IN 21 (1995–2025) OH 20 (1986–2025) MN 20 (1991–2026) TX 15 (1990–2024) OR 11 (1993–2026) MD 11 (1998–2021) IA 10 (2012–2025) NY 10 (1998–2024) AZ 10 (1999–2025) ME 9 (2000–2022) AK 9 (2000–2025) KS 8 (1995–2024) HI 7 (1993–2026) ID 6 (2006–2013) WI 6 (1986–2025) WY 5 (1995–2025) MA 5 (2005–2017) UT 4 (1995–2014) MS 4 (2008–2021) MO 4 (1998–2023) KY 4 (2005–2024) VT 3 (1993–2017) MT 3 (1998–2008) NE 3 (2001–2017) VA 3 (2002–2019) GA 3 (1997–2022) RI 3 (1994–2015) ND 3 (2007–2007) CO 3 (1988–2025) DC 2 (1994–2024) LA 2 (1989–1994) SD 2 (2011–2022) SC 2 (1996–2022) MI 2 (1985–2012)

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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