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14 Ohio opinions name it 1 courts 2002–2025 3 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 |
|---|---|---|
Ron Scheiderer & Associates v. City of Londongreen2 sentences2025A party’s counsel has engaged in frivolous conduct if a “ ‘reasonable inquiry by a party’s counsel of record should [have] reveal[ed] the inadequacy of a claim.’ ” Id., quoting Ron Scheiderer & Assocs. v. London, 81 Ohio St.3d 94, 97-98 (1998). 2023A party’s counsel has engaged in frivolous conduct if a “ ‘reasonable inquiry by a party’s counsel of record should [have] reveal[ed] the inadequacy of a claim.’ ” Id., quoting Ron Scheiderer & Assocs. v. London, 81 Ohio St.3d 94, 97-98 (1998). | 2 | 13 |
Burchett v. Larkingreen2 sentences2015Montgomery No. 15030, 1996 WL 125916 (Mar. 22, 1996). {¶24} Additionally, "[w]hen * * * reasonable inquiry by a party's counsel of record should reveal the inadequacy of a claim, a finding that the counsel of record has engaged in frivolous conduct is justified, as is an award, made within the statutory guidelines, to any party adversely affected by the frivolous conduct." Burchett v. Larkin, 192 Ohio App.3d 418 , 2011-Ohio-684 , 949 N.E.2d 516, ¶ 21 (4th Dist.) quoting Ron Scheiderer & Assoc. v. London, 81 Ohio St.3d 94, 97-98 , 689 N.E.2d 552 (1998). {¶25} If the reviewing court finds the tr 2015Montgomery No. 15030, 1996 WL 125916 (Mar. 22, 1996). {¶24} Additionally, "[w]hen * * * reasonable inquiry by a party's counsel of record should reveal the inadequacy of a claim, a finding that the counsel of record has engaged in frivolous conduct is justified, as is an award, made within the statutory guidelines, to any party adversely affected by the frivolous conduct." Burchett v. Larkin, 192 Ohio App.3d 418 , 2011-Ohio-684 , 949 N.E.2d 516, ¶ 21 (4th Dist.) quoting Ron Scheiderer & Assoc. v. London, 81 Ohio St.3d 94, 97-98 , 689 N.E.2d 552 (1998). {¶25} If the reviewing court finds the tr | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Ceol v. Zion Industries, Inc.
green
1 sentence2011Id. {¶ 21} Additionally, “[w]hen * * * reasonable inquiry by a party’s counsel of record should reveal the inadequacy of a claim, a finding that the counsel of record has engaged in frivolous conduct is justified, as is an award, made within the statutory guidelines, to any party adversely affected by the frivolous conduct.” Ron Scheiderer & Assoc. v. London (1998), 81 Ohio St.3d 94, 97-98 , 689 N.E.2d 552 . {¶ 22} Whether conduct is frivolous is a question of law that an appellate court independently reviews. | 1 | 2011–2011 |
Akron-Canton Waste Oil, Inc. v. Safety-Kleen Oil Services, Inc.
green
2 sentences2009Reasonable inquiry by Jefferson's counsel would have revealed the inadequacy of his claim. {¶ 18} To establish his defamation claim, Jefferson had to prove the following four elements: "(a) a false and defamatory statement concerning another; (b) an unprivileged publication to a third party; (c) fault amounting at least to negligence on the part of the publisher; and (d) either actionability of the statement irrespective of special harm or the existence of special harm caused by the publication." (Internal citations and quotations omitted.) Akron-Canton Waste Oil, Inc. v. Safety-Kleen Oil Serv 2009Reasonable inquiry by Jefferson's counsel would have revealed the inadequacy of his claim. {¶ 18} To establish his defamation claim, Jefferson had to prove the following four elements: "(a) a false and defamatory statement concerning another; (b) an unprivileged publication to a third party; (c) fault amounting at least to negligence on the part of the publisher; and (d) either actionability of the statement irrespective of special harm or the existence of special harm caused by the publication." (Internal citations and quotations omitted.) Akron-Canton Waste Oil, Inc. v. Safety-Kleen Oil Serv | 1 | 2009–2009 |
Riston v. Butler
green
2 sentences2007Riston v. Butler , 149 Ohio App.3d 390 , 2002-Ohio-2308 , 777 N.E.2d 857 , citing Hickman v. *Page 15 Murray (Mar. 22, 1996), Montgomery App. No. CA 15030. "`In other words, a claim is frivolous if it is absolutely clear under the existing law that no reasonable lawyer could argue the claim.'" Id. at ¶ 30, quoting Hickman v. Murray. {¶ 47} The Ohio Supreme Court has stated: {¶ 48} "When a trial court has determined that reasonable inquiry by a party's counsel of record should reveal the inadequacy of a claim, a finding that the counsel of record has engaged in frivolous conduct is justified, a 2007Riston v. Butler , 149 Ohio App.3d 390 , 2002-Ohio-2308 , 777 N.E.2d 857 , citing Hickman v. *Page 15 Murray (Mar. 22, 1996), Montgomery App. No. CA 15030. "`In other words, a claim is frivolous if it is absolutely clear under the existing law that no reasonable lawyer could argue the claim.'" Id. at ¶ 30, quoting Hickman v. Murray. {¶ 47} The Ohio Supreme Court has stated: {¶ 48} "When a trial court has determined that reasonable inquiry by a party's counsel of record should reveal the inadequacy of a claim, a finding that the counsel of record has engaged in frivolous conduct is justified, a | 1 | 2007–2007 |
Crislip v. TCH Liquidating Co.
green
1 sentence2004Crislip v. TCH Liquidating Co. (1990), 52 Ohio St.3d 251 ; Seley v. G.D. | 1 | 2004–2004 |
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.