17 Ohio opinions name it 2 courts 1983–2025 4 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 |
|---|---|---|
Royal Electric Construction Corp. v. Ohio State Universitygreen2 sentences2012R.C. 1343.03(A) provides, “when money becomes due and payable * * * upon all judgment, decrees, and orders of any judicial tribunal for the payment of money arising out of * * * a contract * * * the creditor is entitled to interest * * *.” {¶53} The Supreme Court of Ohio has held that prejudgment interest “is compensation to the plaintiff for the period of time between the accrual of the claim and judgment, regardless of whether the judgment is based on a claim which was liquidated or unliquidated and even if the sum due was not capable of ascertainment until determined by the court.” Royal El 2011Constr. v. Ohio State Univ. (1995), 73 Ohio St.3d 110 , 652 N.E.2d 687 , prejudgment interest is intended to compensate a claimant for the period of time between the accrual of the claim and the final judgment, without regard as to whether the claim was unliquidated or incapable of ascertainment until final judgment is rendered. | 2 | 6 |
Wallace v. Katogreen2 sentences2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007, ¶ 8 .8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 66 Ohio St.3d at 460 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). 2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007 , ¶ 8.8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 66 Ohio St.3d at 460 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). | 2 | 2 |
Norgard v. Brush Wellman, Inc.green2 sentences2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007, ¶ 8 .8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 66 Ohio St.3d at 460 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). 2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007 , ¶ 8.8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 66 Ohio St.3d at 460 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). | 2 | 2 |
Owens v. Purcelgreen1 sentence2025Owens v. Purcel, 2024-Ohio-1514, ¶ 14 (6th Dist.). {¶ 55} The trial court held that appellants’ claims are barred by both the statute of limitations and the statute of repose, and appellants challenge the trial court’s holding on both fronts. | 1 | 1 |
Eagle Realty Invests., Inc. v. Dumongreen1 sentence2024Eagle Realty, 2022-Ohio-4106, at ¶ 26 (1st Dist.). | 1 | 1 |
Hecht v. Levingreen2 sentences2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007, ¶ 8 .8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 66 Ohio St.3d at 460 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). 2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007 , ¶ 8.8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 66 Ohio St.3d at 460 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). | 1 | 1 |
Hecht v. Levingreen1 sentence2024See majority opinion at ¶ 14, citing Norgard v. Brush Wellman, Inc., 2002-Ohio-2007, ¶ 8 .8 {¶ 88} Moreover, as stated above, this court previously consulted the Restatement to determine the accrual rule for one of the causes of action listed in the same clause as libel and slander—malicious prosecution—Froehlich, 2007- Ohio-4161, at ¶ 13-19, and to decide a publication issue in a defamation cause of action, Hecht, 1993-Ohio-110, ¶ 5 ; see also Wallace, 549 U.S. at 389 (consulting the Restatement of the Law 2d, Torts, to define when a false-imprisonment cause of action accrues). | 1 | 1 |
Williams v. Edwardsgreen1 sentence2001See Williams, supra, at 126, 717 N.E.2d at 375 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
University of Tex. Southwestern Medical Center v. Nassar
green
2 sentences2024To be consistent, the court likewise should consult the Restatement in this case. {¶ 89} The Restatement and “textbook tort law,” Nassar, 570 U.S. at 347 , citing Keeton, Dobbs, Keeton & Owen, Prosser and Keeton on the Law of Torts, § 41, at 265 (5th Ed. 1984), indicate that defamation causes of action accrue upon publication of a defamatory statement. 2024To be consistent, the court likewise should consult the Restatement in this case. {¶ 89} The Restatement and “textbook tort law,” Nassar, 570 U.S. at 347 , citing Keeton, Dobbs, Keeton & Owen, Prosser and Keeton on the Law of Torts, § 41, at 265 (5th Ed. 1984), indicate that defamation causes of action accrue upon publication of a defamatory statement. | 2 | 2024–2024 |
Norco Equip. Co. v. Simtrex, Inc.
neutral
1 sentence2015Cuyahoga No. 95914, 2011-Ohio-3688 , in support of its contention. {¶82} Prejudgment interest in a contract claim compensates the plaintiff for the time between the accrual of the claim and the judgment. | 1 | 2015–2015 |
Guccione v. Hustler Magazine
green
2 sentences2011Ohio courts have rejected this argument and reasoned, “To adopt the accrual rule advocated by plaintiff would result in an interpretation of R.C. 2305.11 in which the statute of limitations would never toll in libel cases so long as there were available issues of the alleged libelous publications.” Guccione, 64 Ohio Misc. at 60 , 18 O.O.3d 273 , 413 N.E.2d 860 ; Singh, 2003-Ohio-2314 , 2003 WL 21027897 , ¶ 23. 5 *33 {¶ 9} In this case, there is no allegation that any changes or modifications were made to the 1990 article. 2011Ohio courts have rejected this argument and reasoned, “To adopt the accrual rule advocated by plaintiff would result in an interpretation of R.C. 2305.11 in which the statute of limitations would never toll in libel cases so long as there were available issues of the alleged libelous publications.” Guccione, 64 Ohio Misc. at 60 , 18 O.O.3d 273 , 413 N.E.2d 860 ; Singh, 2003-Ohio-2314 , 2003 WL 21027897 , ¶ 23. 5 *33 {¶ 9} In this case, there is no allegation that any changes or modifications were made to the 1990 article. | 1 | 2011–2011 |
Balson v. Dodds
green
1 sentence2006Balson v. Dodds (1980), 62 Ohio St.2d 287 , paragraph one of syllabus. | 1 | 2006–2006 |
Landis v. Grange Mutual Insurance
green
1 sentence2006Co. (1998), 82 Ohio St.3d 339 , 341 . {¶ 31} R.C. 1343.03 (C) provides for prejudgment interest against a tortfeasor, "* * * if, upon motion of any party to the civil action, the court determines at a hearing held subsequent to the verdict or decision in the civil action that the party required to pay the money failed to make a good faith effort to settle the case and that the party to whom the money is to be paid did not fail to make a good faith effort to settle the case." The statute is also applicable to insurers in cases involving a breach of duty of good faith in settling, handling, and | 1 | 2006–2006 |
Cipra v. Weiland
green
1 sentence2005Comm. (1941), 139 Ohio St. 92 , 22 O.O. 59 , 38 N.E.2d 399 , paragraph one of the syllabus (“Section 1465-94, General Code, providing that no agreement by an injured employee to waive his rights to compensation under the Workmen’s Compensation Act shall be valid, applies only to an agreement made prior to the accrual of the claim or cause of action, or to an agreement of waiver or settlement consummated after such date wherein the consideration is merely nominal”). | 1 | 2005–2005 |
State, Ex Rel. v. Indus. Comm.
neutral
1 sentence2005Comm. (1941), 139 Ohio St. 92 , 22 O.O. 59 , 38 N.E.2d 399 , paragraph one of the syllabus (“Section 1465-94, General Code, providing that no agreement by an injured employee to waive his rights to compensation under the Workmen’s Compensation Act shall be valid, applies only to an agreement made prior to the accrual of the claim or cause of action, or to an agreement of waiver or settlement consummated after such date wherein the consideration is merely nominal”). | 1 | 2005–2005 |
Industrial Commission v. Davis
green
1 sentence1983The application in this case is not the application of a statute of limitations barring a stale claim but, rather, constitutes a bar to the accrual of the claim, which, pursuant to Davis, supra, cannot accrue until the death of the decedent. | 1 | 1983–1983 |
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.