104 Ohio opinions name it 6 courts 1975–2026 23 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 |
|---|---|---|
Fisher v. Mayfieldgreen2 sentences2017This list of factors is not exclusive, but is "intended to be illustrative of the factors that need to be considered." Fisher at 279, fn.2, 551 N.E.2d 1271 . 2013Richland County, Case No. 2012-CA-56 10 This list of factors is not exhaustive and may continue to evolve, but the list is “illustrative of the factors that need to be considered.” Fisher, 49 Ohio St.3d at 279 , 551 N.E. 2d 1271 . {¶24} Appellee relies on Gilham v. Cambridge Home Health Care, Inc. and Crockett v. HCR Manorcare, to argue appellant cannot meet the totality of the circumstances test because the accident occurred on a public roadway, the employer did not exercise control over the accident scene, and the employer did not receive a sufficient benefit from appellant’s presence at the | 2 | 8 |
State v. Wilsongreen2 sentences1993Some courts have interpreted this language to mean that this type of evidence is admissible ‘if it is relevant under Evid.R. 401 and not excluded under Evid.R. 403.’ State v. Wilson (1982), 8 Ohio App.3d 216, 219 [8 OBR 288, 290-291, 456 N.E.2d 1287, 1291 ]. 1993Some courts have interpreted this language to mean that this type of evidence is admissible ‘if it is relevant under Evid.R. 401 and not excluded under Evid.R. 403.’ State v. Wilson (1982), 8 Ohio App.3d 216, 219 [8 OBR 288, 290-291, 456 N.E.2d 1287, 1291 ]. | 2 | 2 |
In Re I.M., Unpublished Decision (12-24-2003)green2 sentences2011This Court has previously held that “the statute does not require the court to list those factors or conditions it found applicable before making its determination that permanent custody is in the child’s best interest.” In re T.S.; In re I.M., Cuyahoga App. Nos. 82669 and 82695, 2003-Ohio-7069 . 2005However, that holding is not shared by this court. {¶ 22} As this court has repeatedly recognized, "the statute does not require the court to list those factors or conditions it found applicable before making its determination that the child cannot be placed with either parent or that permanent custody is in that child's best interest." In re T.M., Cuyahoga App. No. 83933, 2004-Ohio-5222 , at ¶ 32 ; In re I.M., Cuyahoga App. Nos. 82669 82695, 2003-Ohio-7069, at ¶ 27 . | 1 | 9 |
Blakemore v. Blakemoregreen2 sentences2020Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983). {¶24} The Supreme Court of Ohio has created a list of factors to be considered in evaluating a motion for continuance, which includes: the length of delay requested, whether other continuances have been requested and received; inconvenience to litigants, witnesses, and the trial court; whether the delay is for legitimate reasons or dilatory, purposeful, or contrived; whether the defendant contributed to the circumstances giving rise to the request, and any other relevant factors. 2018Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983). {¶ 15} In determining whether a trial court abused its discretion in denying a presentence motion to withdraw a guilty plea, a reviewing court weighs a list of factors, including: (1) whether the prosecution would be prejudiced if the plea was vacated; (2) whether the accused was represented by highly competent counsel; (3) whether the accused was given a full Crim.R. 11 hearing; (4) whether a full hearing was held on the motion; (5) whether the trial court gave full and fair consideration to the motion; (6) whether the mo | 1 | 4 |
Ruckman v. Cubby Drilling, Inc.green2 sentences2022“This list of factors is not exhaustive * * * and an employee may fail to establish one or more of these three factors and still be able to establish the requisite causal connection.” Friebel, 142 Ohio St.3d 425 , 2014-Ohio-4531 , 32 N.E.3d 413, ¶ 14 , citing Fisher at 279, fn. 2 ; Ruckman, 81 Ohio St.3d at 122 , 689 N.E.2d 917 . 2022“This list of factors is not exhaustive * * * and an employee may fail to establish one or more of these three factors and still be able to establish the requisite causal connection.” Friebel, 142 Ohio St.3d 425 , 2014-Ohio-4531 , 32 N.E.3d 413, ¶ 14 , citing Fisher at 279, fn. 2 ; Ruckman, 81 Ohio St.3d at 122 , 689 N.E.2d 917 . | 1 | 3 |
State v. Ungergreen2 sentences2026Analysis {¶21} “The Supreme Court of Ohio has created a list of factors to be considered in evaluating a motion for continuance, which includes: the length of delay requested, whether other continuances have been requested and received; inconvenience to litigants, witnesses, and the trial court; whether the delay is for legitimate reasons or dilatory, purposeful, or contrived; whether the defendant contributed to the circumstances giving rise to the request, and any other relevant factors.” Flinders, at ¶ 24, citing State v. Unger, 67 Ohio St.2d, 65, 68 (1981). {¶22} Upon examining the record 2020Unger, supra, at 68 . | 1 | 2 |
Skerlec v. Ganley Chevrolet, Inc.green2 sentences2026This court has also identified a list of factors to consider in deciding whether a party acted inconsistently with the right to arbitrate: “‘(1) any delay in the requesting party’s demand to arbitrate via a motion to stay judicial proceedings and an order compelling arbitration; (2) the extent of the requesting party’s participation in the litigation prior to its filing a motion to stay the judicial proceeding, including a determination of the status of discovery, dispositive motions, and the trial date; (3) whether the requesting party invoked the jurisdiction of the court by filing a counter 2021Cuyahoga No. 98247, 2012-Ohio-5748, ¶ 24 , quoting Phillips at 12 . | 1 | 2 |
Hudson v. United Statesgreen2 sentences2017Hudson Prong 2-Purpose or Effect {¶ 34} Secondly, under Hudson , even in those cases where the legislature has indicated an intention to establish a civil penalty, courts have inquired further to find "whether the statutory scheme was so punitive in purpose or effect as to transform what was clearly intended to be a civil remedy into a criminal penalty." (Citations omitted.) Martello . {¶ 35} "Only the clearest proof will suffice to override legislative intent and transform what has been denominated a civil remedy into a criminal penalty." Id. at ¶ 20, quoting Hudson , 522 U.S. at 99 , 118 S.C 2017Hudson Prong 2-Purpose or Effect {¶ 34} Secondly, under Hudson , even in those cases where the legislature has indicated an intention to establish a civil penalty, courts have inquired further to find "whether the statutory scheme was so punitive in purpose or effect as to transform what was clearly intended to be a civil remedy into a criminal penalty." (Citations omitted.) Martello . {¶ 35} "Only the clearest proof will suffice to override legislative intent and transform what has been denominated a civil remedy into a criminal penalty." Id. at ¶ 20, quoting Hudson , 522 U.S. at 99 , 118 S.C | 1 | 2 |
State v. Evansgreen2 sentences2013The trial court erred by failing to grant Reed's motion to suppress any evidence that stemmed from his illegal detainment. {¶12} In reaching this conclusion, the Reed court at ¶ 10-11 quoted "a list of factors collected from various cases which may be considered by a court in determining whether an officer had reasonable suspicion to administer field sobriety tests under the totality of the circumstances" from State v. Evans, 127 Ohio App.3d 56, fn. 2 (11th Dist.1998): "(1) the time of day of the stop (Friday or Saturday night as opposed to, e.g., Tuesday morning); (2) the location of the stop 2006In State v. Evans (1998), 127 Ohio App.3d 56 , the Eleventh District noted a list of factors collected from various cases which may be considered by a court in determining whether an officer had reasonable suspicion to administer field sobriety tests under the totality of the circumstances: {¶ 11} "(1) the time of day of the stop (Friday or Saturday night as opposed to, e.g., Tuesday morning); (2) the location of the stop (whether near establishments selling alcohol); (3) any indicia of erratic driving before the stop that may indicate a lack of coordination (speeding, weaving, unusual braking | 1 | 2 |
Layne v. Laynegreen2 sentences2008Layne v. Layne (1992), 83 Ohio App.3d 559 , 562-563 . 1994See Layne v. Layne (1992), 83 Ohio App.3d 559 , 615 N.E.2d 332 . | 1 | 2 |
State v. Corradettigreen1 sentence2025“To achieve those purposes, the sentencing court shall consider the impact of the offense upon the victim and the need for changing the offender’s behavior, rehabilitating the offender, and making restitution to the victim of the offense, the public, or the victim and the public.” R.C. 2929.21(B) directs a trial court to impose a misdemeanor sentence that is reasonably calculated to achieve the two overriding purposes of misdemeanor sentencing “commensurate with and not demeaning to the seriousness of the offender’s conduct and its impact upon the victim, and consistent with sentences imposed | 1 | 1 |
State v. Fromknechtgreen1 sentence2025“To achieve those purposes, the sentencing court shall consider the impact of the offense upon the victim and the need for changing the offender’s behavior, rehabilitating the offender, and making restitution to the victim of the offense, the public, or the victim and the public.” R.C. 2929.21(B) directs a trial court to impose a misdemeanor sentence that is reasonably calculated to achieve the two overriding purposes of misdemeanor sentencing “commensurate with and not demeaning to the seriousness of the offender’s conduct and its impact upon the victim, and consistent with sentences imposed | 1 | 1 |
State v. Pippertgreen2 sentences2025R.C. 3 2929.22(B)(1) also outlines a list of factors courts must consider in determining the appropriate sentence for a misdemeanant. {¶7} “While it is preferable that the trial court state on the record that it has considered the statutory criteria [set forth in R.C. 2929.21 and 2929.22], the [Revised Code] imposes no requirement that it do so.” State v. Pippert, 2016-Ohio-1352, ¶ 23 (9th Dist.), quoting Cuyahoga Falls v. Bradley, 2004-Ohio-4583, ¶ 7 (9th Dist.). 2025R.C. 3 2929.22(B)(1) also outlines a list of factors courts must consider in determining the appropriate sentence for a misdemeanant. {¶7} “While it is preferable that the trial court state on the record that it has considered the statutory criteria [set forth in R.C. 2929.21 and 2929.22], the [Revised Code] imposes no requirement that it do so.” State v. Pippert, 2016-Ohio-1352, ¶ 23 (9th Dist.), quoting Cuyahoga Falls v. Bradley, 2004-Ohio-4583, ¶ 7 (9th Dist.). | 1 | 1 |
City of Cuyahoga Falls v. Bradley, Unpublished Decision (9-1-2004)green2 sentences2025R.C. 3 2929.22(B)(1) also outlines a list of factors courts must consider in determining the appropriate sentence for a misdemeanant. {¶7} “While it is preferable that the trial court state on the record that it has considered the statutory criteria [set forth in R.C. 2929.21 and 2929.22], the [Revised Code] imposes no requirement that it do so.” State v. Pippert, 2016-Ohio-1352, ¶ 23 (9th Dist.), quoting Cuyahoga Falls v. Bradley, 2004-Ohio-4583, ¶ 7 (9th Dist.). 2025R.C. 3 2929.22(B)(1) also outlines a list of factors courts must consider in determining the appropriate sentence for a misdemeanant. {¶7} “While it is preferable that the trial court state on the record that it has considered the statutory criteria [set forth in R.C. 2929.21 and 2929.22], the [Revised Code] imposes no requirement that it do so.” State v. Pippert, 2016-Ohio-1352, ¶ 23 (9th Dist.), quoting Cuyahoga Falls v. Bradley, 2004-Ohio-4583, ¶ 7 (9th Dist.). | 1 | 1 |
| State v. Hillgreen | 1 | 1 |
State v. Bryantgreen1 sentence2025State v. Bryant, 2024-Ohio-1192, ¶ 32 (2d Dist.). {¶ 17} R.C. 2929.11 and R.C. 2929.12 are not fact-finding statutes, and while the sentencing court must “consider” the factors, it is not required to make specific findings on the record regarding its consideration of the factors. | 1 | 1 |
Krill v. Krillgreen1 sentence2025“The trial court ‘has discretion in determining which factors are relevant,’ and ‘each factor may not necessarily carry the same weight or have the same relevance, depending upon the facts before the trial court.’” Krill v. Krill, 2014-Ohio-2577, ¶ 29 (3d Dist.), quoting Brammer v. Brammer, 2013-Ohio-2843, ¶ 41 (3d Dist.). | 1 | 1 |
Brammer v. Brammergreen1 sentence2025“The trial court ‘has discretion in determining which factors are relevant,’ and ‘each factor may not necessarily carry the same weight or have the same relevance, depending upon the facts before the trial court.’” Krill v. Krill, 2014-Ohio-2577, ¶ 29 (3d Dist.), quoting Brammer v. Brammer, 2013-Ohio-2843, ¶ 41 (3d Dist.). | 1 | 1 |
| Chubb v. Ohio Bureau of Workers' Compensationgreen | 1 | 1 |
| Schmidt v. Avco Corp.green | 1 | 1 |
| MTD Products, Inc. v. Robatingreen | 1 | 1 |
| State v. Cuthbertsongreen | 1 | 1 |
| Elwert v. Pilot Life Insurancegreen | 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. McNeil
green
2 sentences2017Athens No. 08CA31, 2009-Ohio-4992 , 2009 WL 3042045 , ¶ 7 ; quoting State v. McNeil , 146 Ohio App.3d 173 , 176, 765 N.E.2d 884 (1st Dist. 2001). 2011Furthermore, “[w]hen applying the abuse of discretion standard, a reviewing court is not free to merely substitute its judgment for that of the trial court.” In re Jane Doe 1 (1991), 57 Ohio St.3d 135, 137-138 , 566 N.E.2d 1181 . {13} We have set forth a list of factors that we consider when determining whether a trial court abused its discretion by denying a presentence motion to withdraw a plea: “‘(1) whether the accused was represented by highly competent counsel, (2) whether the accused was given a full Crim.R. 11 hearing before entering the plea, (3) whether a full hearing was held on the | 7 | 2011–2017 |
Duncan v. Village of Middlefield
green
2 sentences2000The Supreme Court set forth a list of factors to aid in the determination of whether "practical difficulties" exist: "* * * (1) whether the property in question will yield a reasonable return or whether there can be any beneficial use of the property without the variance; (2) whether the variance is substantial; (3) whether the essential character of the neighborhood would be substantially altered or whether adjoining properties would suffer a substantial detriment as a result of the variance; (4) whether the variance would adversely affect the delivery of governmental services * * *; (5) whet 1999The Supreme Court has set forth a list of factors to aid in the determination of whether "practical difficulties" exist: "* * * (1) whether the property in question will yield a reasonable return or whether there can be any beneficial use of the property without the variance; (2) whether the variance is substantial; (3) whether the essential character of the neighborhood would be substantially altered or whether adjoining properties would suffer a substantial detriment as a result of the variance; (4) whether the variance would adversely affect the delivery of governmental services * * *; (5) | 4 | 1999–2005 |
Friebel v. Visiting Nurse Assn. of Mid-Ohio (Slip Opinion)
green
2 sentences2022“This list of factors is not exhaustive * * * and an employee may fail to establish one or more of these three factors and still be able to establish the requisite causal connection.” Friebel, 142 Ohio St.3d 425 , 2014-Ohio-4531 , 32 N.E.3d 413, ¶ 14 , citing Fisher at 279, fn. 2 ; Ruckman, 81 Ohio St.3d at 122 , 689 N.E.2d 917 . 2022“This list of factors is not exhaustive * * * and an employee may fail to establish one or more of these three factors and still be able to establish the requisite causal connection.” Friebel, 142 Ohio St.3d 425 , 2014-Ohio-4531 , 32 N.E.3d 413, ¶ 14 , citing Fisher at 279, fn. 2 ; Ruckman, 81 Ohio St.3d at 122 , 689 N.E.2d 917 . | 3 | 2017–2022 |
Kennedy v. Mendoza-Martinez
green
2 sentences1998The list of factors in Kennedy v. Mendoza-Martinez (1963), 372 U.S. 144 , while not exhaustive or dispositive, provides guidance in making this determination. 1991When employing this second prong, the court in both Ward and One Assor tment of Firearms used a list of factors first enunciated in Kennedy v. Mendoza-Martinez (1963), 372 U.S. 144, 168-169 . | 3 | 1991–2017 |
In re Jane Doe 1
green
2 sentences2013Furthermore, “[w]hen applying the abuse of discretion standard, a reviewing court is not free to merely substitute its judgment for that of the trial court.” In re Jane Doe 1, 57 Ohio St.3d 135, 137-138 , 566 N.E.2d 1181 (1991). {¶ 17} We have set forth a list of factors that we consider when determining whether a trial court abused its discretion by denying a presentence motion to withdraw a plea: “ ‘(1) whether the accused was represented by highly competent counsel, (2) whether the accused was given a full Crim.R. 11 hearing before entering the plea, (3) whether a full hearing was held on t 2013Furthermore, “[w]hen applying the abuse of discretion standard, a reviewing court is not free to merely substitute its judgment for that of the trial court.” In re Jane Doe 1, 57 Ohio St.3d 135, 137-138 , 566 N.E.2d 1181 (1991). {¶ 17} We have set forth a list of factors that we consider when determining whether a trial court abused its discretion by denying a presentence motion to withdraw a plea: “ ‘(1) whether the accused was represented by highly competent counsel, (2) whether the accused was given a full Crim.R. 11 hearing before entering the plea, (3) whether a full hearing was held on t | 3 | 2011–2013 |
Bunten v. Bunten
green
2 sentences2011Bunten v. Bunten -18- Case No. 13-10-39 (1998), 126 Ohio App.3d 443, 447 , 710 N.E.2d 757 , citing Masitto v. Masitto (1986), 22 Ohio St.3d 63 , 488 N.E.2d 857 . {¶34} In this case, the trial court provided an analysis of the evidence adduced at trial, applying that evidence to each and every factor in R.C. 3109.04, setting forth in precise detail its reasons for reallocating parental rights. 2011Bunten v. Bunten -18- Case No. 13-10-39 (1998), 126 Ohio App.3d 443, 447 , 710 N.E.2d 757 , citing Masitto v. Masitto (1986), 22 Ohio St.3d 63 , 488 N.E.2d 857 . {¶34} In this case, the trial court provided an analysis of the evidence adduced at trial, applying that evidence to each and every factor in R.C. 3109.04, setting forth in precise detail its reasons for reallocating parental rights. | 3 | 2009–2011 |
Masitto v. Masitto
green
2 sentences2011Bunten v. Bunten -18- Case No. 13-10-39 (1998), 126 Ohio App.3d 443, 447 , 710 N.E.2d 757 , citing Masitto v. Masitto (1986), 22 Ohio St.3d 63 , 488 N.E.2d 857 . {¶34} In this case, the trial court provided an analysis of the evidence adduced at trial, applying that evidence to each and every factor in R.C. 3109.04, setting forth in precise detail its reasons for reallocating parental rights. 2011Bunten v. Bunten -18- Case No. 13-10-39 (1998), 126 Ohio App.3d 443, 447 , 710 N.E.2d 757 , citing Masitto v. Masitto (1986), 22 Ohio St.3d 63 , 488 N.E.2d 857 . {¶34} In this case, the trial court provided an analysis of the evidence adduced at trial, applying that evidence to each and every factor in R.C. 3109.04, setting forth in precise detail its reasons for reallocating parental rights. | 3 | 2009–2011 |
Reed v. Reed
green
2 sentences2025Additionally, “[d]uring the pendency of any divorce * * * the court may award reasonable temporary spousal support to either party.” Id. {¶62} R.C. 3105.18(C)(1) contains a list of factors to be considered by a court in determining whether spousal support should be ordered, and provides: In determining whether spousal support is appropriate and reasonable, and in determining the nature, amount, and terms of payment, and duration of spousal support, which is payable either in gross or in installments, the court shall consider all of the following factors: (a) The income of the parties, from all 2024Reed, supra, at ¶ 42 . {¶33} In the instant case, the magistrate’s decision contains the following findings and recommendation with regard to spousal support, also adopted and incorporated into the trial court’s final judgment: Considering Husband’s and Wife’s income, after tax, and guideline child support, a disparity in income between the Parties equals $20,216.29. | 2 | 2024–2025 |
State ex rel. Davis v. Public Employees Retirement Board
green
2 sentences2021Bd., 111 Ohio St.3d 118 , 2006- Ohio-5339, ¶ 28, quoting Schmidt v. Avco Corp., 15 Ohio St.3d 310, 313 (1984). {¶ 17} Civ.R. 23(B)(3) sets forth a list of factors "pertinent" to both the predominance and superiority findings required under Civ.R. 23(B)(3): (1) "the class members' interests in individually controlling the prosecution or defense of separate actions"; (2) "the extent and nature of any litigation concerning the controversy already begun by or against class members"; (3) "the desirability or undesirability of concentrating the litigation of the claims in the particular forum"; and 2018"The list in the rule is not exhaustive, so other pertinent factors may be considered." Davis , 111 Ohio St.3d 118 , 2006-Ohio-5339 , 855 N.E.2d 444 , at ¶ 28. {¶ 62} As we recognized before, there are a number of standards that the courts have used to determine predominance: the substantive elements of class members' claims require the same proof for each class member; the proposed class is bound together by a mutual interest in resolving common questions more than it is divided by individual interests; the resolution of an issue common to the class would significantly advance the litigation; | 2 | 2018–2021 |
State v. Calhoun
green
2 sentences2003Calhoun , 86 Ohio St.3d at 285 . 2001Calhoun, 86 Ohio St.3d at 285 . | 2 | 2001–2003 |
State v. Thompson
green
2 sentences2002State v. Thompson (2001), 92 Ohio St.3d 584 , 752 N.E.2d 276 , 2001-Ohio-1288 . 2002Id. | 2 | 2002–2002 |
State v. Reynolds
green
2 sentences2000In Reynolds, 80 Ohio St.3d at 684 , 687 N.E.2d at 1372 , this court focused on several factors to find that the defendant was not prejudiced, stating, “A court’s error in failing to ask a defendant if he wants to make a statement prior to sentencing is not prejudicial where, as here, the defendant makes an unsworn statement in the penalty phase, sends a letter to the trial court, and where defense counsel makes a statement on behalf of the defendant.” Obviously, the list of factors in Reynolds is not an exhaustive one, and that case illustrates that prejudice on this issue must be determined o 2000In Reynolds, 80 Ohio St.3d at 684 , 687 N.E.2d at 1372 , this court focused on several factors to find that the defendant was not prejudiced, stating, “A court’s error in failing to ask a defendant if he wants to make a statement prior to sentencing is not prejudicial where, as here, the defendant makes an unsworn statement in the penalty phase, sends a letter to the trial court, and where defense counsel makes a statement on behalf of the defendant.” Obviously, the list of factors in Reynolds is not an exhaustive one, and that case illustrates that prejudice on this issue must be determined o | 2 | 2000–2000 |
State v. Davis
green
1 sentence2026Id. {¶ 29} R.C. 2929.12 contains a list of factors to be considered by the trial court when imposing a sentence under R.C. 2929.11, underscoring that a court imposing a sentence on an offender for a felony has discretion to determine the most effective way to comply with the purposes and principles of sentencing. | 1 | 2026–2026 |
| Neil v. Biggers green | 1 | 2025–2025 |
| Schwieterman v. Schwieterman green | 1 | 2024–2024 |
| State v. Reed, Unpublished Decision (12-19-2006) green | 1 | 2024–2024 |
| Sivertsen-Kuhn v. Kuhn neutral | 1 | 2024–2024 |
| In re A.M. (Slip Opinion) green | 1 | 2023–2023 |
| Briganti v. Briganti green | 1 | 2021–2021 |
| Moell v. Moell green | 1 | 2021–2021 |
| State v. Evans, Unpublished Decision (11-7-2007) neutral | 1 | 2021–2021 |
| Hoffman v. Gallia Cnty. Sheriff's Office green | 1 | 2020–2020 |
| Cichanowicz v. Cichanowicz green | 1 | 2020–2020 |
| Ohio Casualty Ins. v. Travelers Indemnity Co. green | 1 | 2019–2019 |
| State v. Burris green | 1 | 2019–2019 |
| In Re B.C. green | 1 | 2018–2018 |
| State v. Adams green | 1 | 2017–2017 |
| State v. Becraft green | 1 | 2017–2017 |
| State v. Coleman neutral | 1 | 2017–2017 |
| State v. Hoke green | 1 | 2017–2017 |
| State v. Funk, Unpublished Decision (4-27-2006) green | 1 | 2017–2017 |
| Industrial Commission v. Henry green | 1 | 2016–2016 |
| Thomas v. Thomas green | 1 | 2015–2015 |
| State v. Darmond green | 1 | 2014–2014 |
| Lombardo v. Ohio Bureau of Employment Services green | 1 | 2014–2014 |
| State v. Arnett green | 1 | 2013–2013 |
| State v. Fish green | 1 | 2011–2011 |
| Rohde v. Farmer green | 1 | 2010–2010 |
| Lord v. Daugherty green | 1 | 2010–2010 |
| Calame v. Treece, 07ca0073 (9-30-2008) neutral | 1 | 2010–2010 |
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.