19 Ohio opinions name it 2 courts 2005–2025 9 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 |
|---|---|---|
Lamb's Chapel v. Center Moriches Union Free School Districtgreen2 sentences2024Moriches Union Free School Dist., 508 U.S. 384, 398 (1993) (Scalia, J., concurring in the judgment). 2024Moriches Union Free School Dist., 508 U.S. 384 , 398 (1993) (Scalia, J., concurring in the judgment). | 2 | 2 |
State ex rel. Ullmann v. Husted (Slip Opinion)green2 sentences2024But this court continues to treat this form of standing, and the litigants who rely on it, dismissively.” [citation omitted]); Ullmann at ¶ 16 (O’Neill, J., dissenting) (“I would hold that [the relator] has standing under the public-right doctrine”). {¶ 23} The Sheward public-right doctrine has become this court’s “ghoul in a late-night horror movie that repeatedly sits up in its grave and shuffles abroad,” Lamb’s Chapel v. Ctr. 2024But this court continues to treat this form of standing, and the litigants who rely on it, dismissively.” [citation omitted]); Ullmann at ¶ 16 (O’Neill, J., dissenting) (“I would hold that [the relator] has standing under the public-right doctrine”). {¶ 23} The Sheward public-right doctrine has become this court’s “ghoul in a late-night horror movie that repeatedly sits up in its grave and shuffles abroad,” Lamb’s Chapel v. Ctr. | 2 | 2 |
State ex rel. Ohio Academy of Trial Lawyers v. Shewardgreen2 sentences2025Ohio Academy of Trial Lawyers v. Sheward, 86 Ohio St.3d 451 (1999), and no longer permits parties to assert the public- right doctrine as a means to “bypass” the standing requirement. 2022The public-right doctrine presents “an exception to the personal- injury requirement of standing.” Sheward, 86 Ohio St.3d at 503 , 715 N.E.2d 1062 . | 1 | 9 |
ProgressOhio.org, Inc. v. JobsOhio (Slip Opinion)green2 sentences2021“The public-right doctrine represents ‘an exception to the personal-injury requirement of standing.’ ” ProgressOhio.org, Inc. v. JobsOhio, 139 Ohio St.3d 520 , 2014-Ohio-2382 , 13 N.E.3d 1101, ¶ 9 , quoting State ex rel. 2021“The public-right doctrine represents ‘an exception to the personal-injury requirement of standing.’ ” ProgressOhio.org, Inc. v. JobsOhio, 139 Ohio St.3d 520 , 2014-Ohio-2382 , 13 N.E.3d 1101, ¶ 9 , quoting State ex rel. | 1 | 6 |
State ex rel. Ohio Academy of Trial Lawyers v. Shewardgreen2 sentences2025Ohio Academy of Trial Lawyers v. Sheward, 1999-Ohio-123 , 86 Ohio St.3d No. 25AP-356 6 451. 2025Ohio Academy of Trial Lawyers v. Sheward, 1999-Ohio-123 . | 1 | 3 |
State ex rel. Leslie v. Ohio Housing Finance Agencygreen2 sentences2015Agency, 105 Ohio St.3d 261 , 2005-Ohio-1508 , 824 N.E.2d No. 14AP-863 11 990, quoting Sheward at 504, 715 N.E.2d 1062 (constitutional challenge to state spending measures was "not a 'rare and extraordinary case' warranting invocation of the public-right exception to the personal-stake requirement of standing"). 2014Agency, 105 Ohio St.3d 261 , 2005- Ohio-1508, 824 N.E.2d 990 , quoting Sheward at 504 (constitutional challenge to state spending measures was “not a ‘rare and extraordinary case’ warranting invocation of the public-right exception to the personal-stake requirement of standing”). | 1 | 3 |
State ex rel. Caspar v. City of Daytongreen1 sentence2024Caspar v. Dayton, 53 Ohio St.3d 16, 20 (1990). {¶22} This public-right requirement prevents “mere interlopers” attempting to “‘“‘meddle with the affairs of the state, and [taxpayer suits are] not usually allowed unless under circumstances when the public injury by its refusal will be serious.’”’” (Emphasis in Teamsters.) State ex rel. | 1 | 1 |
State ex rel. Food & Water Watch v. Stategreen2 sentences2021Food and Water Watch v. State, 153 Ohio St.3d 1 , 2018-Ohio-555, ¶ 31 (“This court has not granted a public-right-doctrine exception to standing pursuant to Sheward in the past 15 years, and we decline to do so today.”); ProgressOhio.org, Inc. at ¶ 13 (“Sheward was a deeply divided, four-to-three decision, and it remains controversial today.”). 2021Food and Water Watch v. State, 153 Ohio St.3d 1 , 2018-Ohio-555, ¶ 31 (“This court has not granted a public-right-doctrine exception to standing pursuant to Sheward in the past 15 years, and we decline to do so today.”); ProgressOhio.org, Inc. at ¶ 13 (“Sheward was a deeply divided, four-to-three decision, and it remains controversial today.”). | 1 | 1 |
Clapper v. Amnesty International USAgreen1 sentence2015USA, 133 S.Ct. 1138, 1150 (2013) (holding that in order to establish injury-in-fact based on a potential future injury, that injury must be "certainly impending," a test not established by the appellant's "speculative chain of possibilities"). {¶ 20} Here, the complaint alleges appellant is an Ohio resident living with an HIV infection who currently utilizes OHDAP, a program which supplies potentially life- saving drugs which can cost as much as $10,000-$40,000 per year, per patient. 4 Under the public-right doctrine outlined in Sheward, a plaintiff may also assert threatened injuries involvin | 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 ex rel. Martens v. Findlay Mun. Court
green
2 sentences2025However, in a previous mandamus action brought by Martens, we expressly overruled the Sheward public- right doctrine as “contrary to our deeply rooted standing requirement and the Ohio Constitution.” Martens IV, 2024-Ohio-5667, at ¶ 3 . {¶ 19} Because Martens lacked standing to bring his mandamus action, the Third District correctly granted the city’s motion to dismiss his second amended complaint. 2024Court, 2024-Ohio-5667 .] Mandamus—Standing—Public-right doctrine—State ex rel. | 2 | 2024–2025 |
State ex rel. Countryside Investors, L.L.C. v. Carroll Cty. Bd. of Commrs.
neutral
1 sentence2019No. 13 CA 885, 2015-Ohio-4344, ¶ 36 . {¶ 27} In Fisher, the Supreme Court considered whether the relators satisfied the public right requirement where they sought to enjoin the city from requiring municipal employees to submit copies of their tax returns in order to prove they satisfied the city's residency requirement. | 1 | 2019–2019 |
Sierra Club v. Morton
green
1 sentence2016The doctrine provides that "when the issues sought to be litigated are of great importance and interest to the public, they may be resolved in a form of action that involves no rights or obligations peculiar to named parties." Id. at 471 . | 1 | 2016–2016 |
Bowers v. Ohio State Dental Board
green
1 sentence2005Moreover, "[t]he vast majority of such cases involve voting rights and ballot disputes." Id. {¶ 11} In the present case, the challenged statute is not the type of legislation of a magnitude or comparable to the tort reform enactment in Sheward, and we agree with the trial court that this is not the "rare and extraordinary case" that would give rise to application of the public-right doctrine. | 1 | 2005–2005 |
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.
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.