statute imposes requirement (Ohio) · Go Syfert
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statute imposes requirement in Ohio

15 Ohio opinions name it 2 courts 1959–2025 8 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 (4)

CaseFollowedCited
In re L.R.green
ohioctapp · 2019 · cited in 8 Ohio opinions naming this issue, 2021–2025
2 sentences

2025It is well settled that “the statute imposes no requirement for such a determination at the time of the permanent custody hearing unless the agency has not established that reasonable efforts have been made prior to that hearing.” (Internal quotations omitted.) In re L.R., 2019-Ohio-2305, ¶ 14 (9th Dist.), quoting In re A.C.-B., 10 2017-Ohio-374, ¶ 22 (9th Dist.); see also In re C.F., 2007-Ohio-1104 , ¶ 41-43 (concluding that a reasonable efforts determination is necessary at a permanent custody hearing only if the agency has not demonstrated its use of reasonable efforts prior to that time).

2024It is well settled that “the statute imposes no requirement for such a determination at the time of the permanent custody hearing unless the agency has not established that reasonable efforts have been made prior to that hearing.” (Internal quotations omitted.) In re L.R., 2019-Ohio-2305, ¶ 14 (9th Dist.), quoting In re A.C.-B., 2017-Ohio-374, ¶ 22 (9th Dist.); see also In re C.F., 2007-Ohio-1104 , ¶ 41-43 (concluding that a 22 reasonable efforts determination is necessary at a permanent custody hearing only if the agency has not demonstrated its use of reasonable efforts prior to that time).

38
In re A.C.-B.green
ohioctapp · 2017 · cited in 2 Ohio opinions naming this issue, 2024–2025
2 sentences

2025It is well settled that “the statute imposes no requirement for such a determination at the time of the permanent custody hearing unless the agency has not established that reasonable efforts have been made prior to that hearing.” (Internal quotations omitted.) In re L.R., 2019-Ohio-2305, ¶ 14 (9th Dist.), quoting In re A.C.-B., 10 2017-Ohio-374, ¶ 22 (9th Dist.); see also In re C.F., 2007-Ohio-1104 , ¶ 41-43 (concluding that a reasonable efforts determination is necessary at a permanent custody hearing only if the agency has not demonstrated its use of reasonable efforts prior to that time).

2024It is well settled that “the statute imposes no requirement for such a determination at the time of the permanent custody hearing unless the agency has not established that reasonable efforts have been made prior to that hearing.” (Internal quotations omitted.) In re L.R., 2019-Ohio-2305, ¶ 14 (9th Dist.), quoting In re A.C.-B., 2017-Ohio-374, ¶ 22 (9th Dist.); see also In re C.F., 2007-Ohio-1104 , ¶ 41-43 (concluding that a 22 reasonable efforts determination is necessary at a permanent custody hearing only if the agency has not demonstrated its use of reasonable efforts prior to that time).

22
State v. Polickgreen
ohioctapp · 1995 · cited in 2 Ohio opinions naming this issue, 2006–2016
2 sentences

2016“While it 9 is preferable that the trial court state on the record that it has considered the statutory criteria, the statute imposes no requirement that it do so.” Bradley, 2004-Ohio-4583 at ¶ 7 , citing State v. Polick, 101 Ohio App.3d 428, 431 (4th Dist.1995).

2006Id., citing State v. Polick (1995), 101 Ohio App.3d 428 , 431 .

12
In re J.W.green
ohioctapp · 2018 · cited in 1 Ohio opinions naming this issue, 2019–2019
1 sentence

2019Summit Nos. 28966 and 28976, 2018-Ohio-3897, ¶ 6 (superseded in part on other grounds), quoting In re A.C.-B., 9th Dist.

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 (8)

CaseCitedYears
Koudela v. Johnson & Johnson Custom Builders, L.LC. green
ohioctapp · 2017
1 sentence

2018Lake No. 2017-L-024, 2017-Ohio-9331 , 2017 WL 6729380 , ¶ 10. {¶ 17} R.C. 2711.02(B) states: "If any action is brought upon any issue referable to arbitration under an agreement in writing for arbitration, the court in which the action is pending, upon being satisfied that the issue involved in the action is referable to arbitration under an agreement in writing for arbitration, shall on application of one of the parties stay the trial of the action until the arbitration of the issue has been had in accordance with the agreement, provided the applicant for the stay is not in default in proceed

12018–2018
City of Cuyahoga Falls v. Bradley, Unpublished Decision (9-1-2004) green
ohioctapp · 2004
1 sentence

2016“While it 9 is preferable that the trial court state on the record that it has considered the statutory criteria, the statute imposes no requirement that it do so.” Bradley, 2004-Ohio-4583 at ¶ 7 , citing State v. Polick, 101 Ohio App.3d 428, 431 (4th Dist.1995).

12016–2016
Berry v. Lupica, 90657 (10-2-2008) neutral
ohioctapp · 2008
1 sentence

2012No. 90657, 2008-Ohio-5102 , 2008 WL 4438444 , ¶ 7. {¶ 7} The arbitration statute, R.C. 2711.02(B), provides as follows: If any action is brought upon any issue referable to arbitration under an agreement in writing for arbitration, the court in which the action is pending, upon being satisfied that the issue involved in the action is referable to arbitration under an agreement in writing for arbitration, shall on application of one of the parties stay the trial of the action until the arbitration of the issue has been had in accordance with the agreement, provided the applicant for the stay is

12012–2012
In Re Estate of Voegeli green
ohioctapp · 1959
1 sentence

1964After all, upon deposit of an account, the bank is constituted a debtor, and when the depositor orders the bank to pay himself or another, upon order of either party, notifies the second party of the completed transaction and secures her signature, evidencing assent to the arrangement, he has created in the second party by contract a joint interest in his right to the deposit equal to his own.” At page 376 in Judge Fess’ opinion in the case of In re Estate of Voegeli, supra, we find this observation by the Judge: “In passing, it may be observed that the statute imposes no requirement that the

11964–1964
In Re Estate of Kessler neutral
ohioctapp · 1949
1 sentence

1959In re Estate of Hutchison, 120 Ohio St., 542 , 166 N. E., 687 ; Sage, Admr., v. Flueck, supra; In re Estate of Hatch, supra; In re Estate of Kessler, supra. See comment distinguishing the Scobie case in Bauman v. Walter, supra ( 160 Ohio St., 273 ), 276-277.

11959–1959
In Re Estate of Hatch green
· 1950
1 sentence

1959In re Estate of Hutchison, 120 Ohio St., 542 , 166 N. E., 687 ; Sage, Admr., v. Flueck, supra; In re Estate of Hatch, supra; In re Estate of Kessler, supra. See comment distinguishing the Scobie case in Bauman v. Walter, supra ( 160 Ohio St., 273 ), 276-277.

11959–1959
Sage v. Flueck green
· 1937
1 sentence

1959In re Estate of Hutchison, 120 Ohio St., 542 , 166 N. E., 687 ; Sage, Admr., v. Flueck, supra; In re Estate of Hatch, supra; In re Estate of Kessler, supra. See comment distinguishing the Scobie case in Bauman v. Walter, supra ( 160 Ohio St., 273 ), 276-277.

11959–1959
In Re Estate of Hutchison green
· 1929
2 sentences

1959In re Estate of Hutchison, 120 Ohio St., 542 , 166 N. E., 687 ; Sage, Admr., v. Flueck, supra; In re Estate of Hatch, supra; In re Estate of Kessler, supra. See comment distinguishing the Scobie case in Bauman v. Walter, supra ( 160 Ohio St., 273 ), 276-277.

1959In re Estate of Hutchison, 120 Ohio St., 542 , 166 N. E., 687 ; Sage, Admr., v. Flueck, supra; In re Estate of Hatch, supra; In re Estate of Kessler, supra. See comment distinguishing the Scobie case in Bauman v. Walter, supra ( 160 Ohio St., 273 ), 276-277.

11959–1959

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2151.419 (9) OH § Ohio Rev. Code § 2151.414 (6) OH § Ohio Rev. Code § 2151.412 (4)

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

TX 16 (2015–2023) OH 15 (1959–2025) CA 6 (1988–2017) NY 6 (1947–2012) FL 5 (1986–2021) MA 3 (2001–2008) CT 2 (2004–2016) OR 2 (2026–2026) NE 2 (1947–1978) TN 2 (1928–1981) IA 2 (2021–2023) MO 2 (2001–2013) IL 2 (1986–1992) CO 2 (1994–2007)

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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