unconscionability doctrine (Ohio) · Go Syfert
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unconscionability doctrine in Ohio

15 Ohio opinions name it 2 courts 1989–2026 2 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 (5)

CaseFollowedCited
Widok v. Estate of Wolfgreen
ohioctapp · 2020 · cited in 1 Ohio opinions naming this issue, 2026–2026
1 sentence

2026“Contract formation requires an offer, acceptance, consideration, and mutual assent between two or more parties with the legal capacity to act.” (Emphasis added.) Widok v. Estate of Wolf, 2020-Ohio-5178, ¶ 52 (8th Dist.), citing Kostelnik v. Helper, 2002-Ohio-2985, ¶ 16 .

11
English v. Cornwell Quality Tools, Co., Unpublished Decision (12-30-2005)green
ohioctapp · 2005 · cited in 1 Ohio opinions naming this issue, 2023–2023
1 sentence

2023Summit No. 22578, 2005-Ohio-6983, ¶ 17 (and distinguishing Porpora as involving a condition precedent to arbitration). {¶46} In any event, Appellant failed to prove this unconscionability claim.

11
Collins v. Click Camera & Video, Inc.green
ohioctapp · 1993 · cited in 1 Ohio opinions naming this issue, 2015–2015
1 sentence

2015Id., quoting Collins v. Click Camera & Video, Inc., 86 Ohio App.3d 826, 834 (1993). {¶31} Regarding any factual finding made by a trial court in an unconscionability analysis, an appellate court is required to accord due deference to the finding.

11
Lake Ridge Academy v. Carneygreen
ohio · 1993 · cited in 1 Ohio opinions naming this issue, 2008–2008
1 sentence

2008Perillo, Corbin On Contracts: Damages, § 58.1, at 396 (rev. ed. 2005). {¶ 13} As noted by the Ohio Supreme Court in Lake Ridge Academy , "[a] penalty is designed to coerce performance by punishing nonperformance; its principal object is not compensation for losses suffered by the nonbreaching party." Lake Ridge Academy , 66 Ohio St. 3d at 381 (emphasis in original).

11
Fotomat Corp. of Fla. v. Chandagreen
fladistctapp · 1985 · cited in 1 Ohio opinions naming this issue, 1993–1993
2 sentences

1993See Chanda, supra, 464 So.2d at 628 ; Orlett, supra, 54 Ohio App.3d at 129 , 561 N.E.2d at 1069 .

1993See Chanda, supra, 464 So.2d at 628 ; Orlett, supra, 54 Ohio App.3d at 129 , 561 N.E.2d at 1069 .

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 (10)

CaseCitedYears
Dorsey v. Contemporary Obstetrics & Gynecology, Inc. green
ohioctapp · 1996
2 sentences

2010“The unconscionability doctrine consists of two prongs: ‘(1) substantive unconscionability, i.e., unfair and unreasonable contract terms, and (2) procedural unconscionability, i.e., individualized circumstances surrounding parties to a contract such that no voluntary meeting of the minds was possible.’ ” Leach, 2002-Ohio-2237 , 2002 WL 926759 , at ¶ 57, quoting Dorsey, 113 Ohio App.3d at 80 , 680 N.E.2d 240 .

2010“The unconscionability doctrine consists of two prongs: ‘(1) substantive unconscionability, i.e., unfair and unreasonable contract terms, and (2) procedural unconscionability, i.e., individualized circumstances surrounding parties to a contract such that no voluntary meeting of the minds was possible.’ ” Leach, 2002-Ohio-2237 , 2002 WL 926759 , at ¶ 57, quoting Dorsey, 113 Ohio App.3d at 80 , 680 N.E.2d 240 .

52001–2010
Taylor Building Corp. of America v. Benfield green
ohio · 2008
2 sentences

2023As the Supreme Court pointed out, “arbitration is favored because it provides the parties thereto Case No. 22 MA 0024 – 15 – with a relatively expeditious and economical means of resolving a dispute.” Hayes, 122 Ohio St.3d 63 at ¶ 15 . “[T]he United States Supreme Court held that an arbitration agreement that does not mention costs and fees is not per se unenforceable on the theory that it fails to protect a party from potentially high arbitration costs, because the mere risk that a plaintiff would be forced to pay exorbitant costs is too speculative to justify invalidation of the arbitration

2009Corp. of Am. v. Benfield, 117 Ohio St.3d 352 , 2008-Ohio-938 , 884 N.E.2d 12 .

22009–2023
Patterson v. ITT Consumer Financial Corp. green
calctapp · 1993
2 sentences

1998Corp. (Cal.App.1993), 14 Cal. App.4th 1659 , 18 Cal.Rptr.2d 563 — a case where a California appellate court found a similar agreement to arbitrate disputes between a plaintiff and ITT before the National Arbitration ■ Forum (“NAF”) unconscionable.

1998Corp. (Cal.App.1993), 14 Cal. App.4th 1659 , 18 Cal.Rptr.2d 563 — a case where a California appellate court found a similar agreement to arbitrate disputes between a plaintiff and ITT before the National Arbitration ■ Forum (“NAF”) unconscionable.

21998–1998
Kostelnik v. Helper green
ohio · 2002
1 sentence

2026“Contract formation requires an offer, acceptance, consideration, and mutual assent between two or more parties with the legal capacity to act.” (Emphasis added.) Widok v. Estate of Wolf, 2020-Ohio-5178, ¶ 52 (8th Dist.), citing Kostelnik v. Helper, 2002-Ohio-2985, ¶ 16 .

12026–2026
Hayes v. Oakridge Home green
ohio · 2009
1 sentence

2023As the Supreme Court pointed out, “arbitration is favored because it provides the parties thereto Case No. 22 MA 0024 – 15 – with a relatively expeditious and economical means of resolving a dispute.” Hayes, 122 Ohio St.3d 63 at ¶ 15 . “[T]he United States Supreme Court held that an arbitration agreement that does not mention costs and fees is not per se unenforceable on the theory that it fails to protect a party from potentially high arbitration costs, because the mere risk that a plaintiff would be forced to pay exorbitant costs is too speculative to justify invalidation of the arbitration

12023–2023
Schwartz v. Alltel Corp., Unpublished Decision (6-29-2006) green
ohioctapp · 2006
1 sentence

2007Finally, in Schwartz v. Alltel Corp. , Cuyahoga App. No. 86810, 2006-Ohio-3353 , this court applied the same two-part unconscionability test to a noncommercial, i.e., consumer, transaction.

12007–2007
Jeffrey Mining Products, L.P. v. Left Fork Mining Co. green
ohioctapp · 2001
1 sentence

2005Jeffrey Mining Prod., L.P. v. Left Fork Mining Co. (2001), 143 Ohio App.3d 708 , 718 . {¶ 10} "The unconscionability doctrine consists of two prongs: (1) substantive unconscionability, i.e., unfair and unreasonable contract terms, and (2) procedural unconscionability, i.e., individualized circumstances surrounding parties to a contract such that no voluntary meeting of the minds was possible." Dorsey, supra, at 80 .

12005–2005
Insurance Co. of North America v. Automatic Sprinkler Corp. of America green
ohio · 1981
1 sentence

2002Co. of North America v. Automatic Sprinkler Corp. (1981), 67 Ohio St.2d 91 , 98 . {¶ 13} In Dorsey v. Contemporary Obstetrics Gynecology, Inc. (1996), 113 Ohio App.3d 75 , 80 , the Second District Court of Appeals set forth a two prong test for the doctrine of unconscionability: {¶ 14} "(1) substantive unconscionability unfair and unreasonable contract terms; and {¶ 15} "(2) procedural unconscionability individualized circumstances surrounding each of the parties to a contract such that no voluntary meeting of the minds was possible." {¶ 16} "Substantive unconscionability is the product of unf

12002–2002
Orlett v. Suburban Propane green
ohioctapp · 1989
2 sentences

1993See Chanda, supra, 464 So.2d at 628 ; Orlett, supra, 54 Ohio App.3d at 129 , 561 N.E.2d at 1069 .

1993See Chanda, supra, 464 So.2d at 628 ; Orlett, supra, 54 Ohio App.3d at 129 , 561 N.E.2d at 1069 .

11993–1993
Salt River Project Agricultural Improvement & Power District v. Westinghouse Electric Corp. green
ariz · 1984
1 sentence

1989As to appellant’s first challenge, we agree with the Arizona Supreme Court that “[although a commercial purchaser is not doomed to failure in pressing an unconscionability claim, * * * findings of unconscionability in a commercial setting are rare.” Salt River Project, supra, at 374, 694 P. 2d at 204 (citing White & Summers, Uniform Commercial Code [1972] 385-386).

11989–1989

Statutes the citing opinions construe

OH § Ohio Rev. Code § 2711.01 (6) OH § Ohio Rev. Code § 2711.02 (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

CA 247 (1982–2026) NY 28 (1973–2023) TX 27 (1995–2026) OH 15 (1989–2026) WA 15 (1990–2023) NM 14 (2011–2024) WV 14 (1998–2025) PA 14 (1978–2023) NJ 13 (1976–2026) IL 12 (1979–2025) FL 11 (1988–2017) CT 11 (1979–2022) AL 10 (1977–2004) SC 8 (2007–2023) CO 7 (1976–2011) MD 7 (1986–2022) NC 7 (2007–2020) VA 7 (2009–2026) IA 7 (1979–2023) UT 7 (1998–2024) WI 7 (1983–2025) AZ 6 (1984–2019) MO 6 (1979–2017) DC 6 (1971–2021) MA 5 (1994–2024) OR 5 (1987–2014) DE 5 (1978–2025) TN 5 (2009–2020) MS 4 (2000–2018) ID 4 (1988–2022) MI 4 (1976–2023) KY 4 (2008–2023) KS 4 (1982–2006) SD 3 (1994–1997) MT 2 (2013–2016) IN 2 (2001–2017) ND 2 (1974–2019) MN 2 (1986–1987)

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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