unfounded claim (Ohio) · Go Syfert
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unfounded claim in Ohio

14 Ohio opinions name it 3 courts 2000–2024 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.

Followed or applied (7)

CaseFollowedCited
Colquhoun v. Webbergreen
me · 1996 · cited in 4 Ohio opinions naming this issue, 2000–2024
2 sentences

2024To prevail on a slander of title claim, “a claimant must prove ‘(1) there was a publication of a slanderous statement disparaging claimant's title; (2) the statement was false; (3) the statement was made with malice or made with reckless disregard of its falsity; and (4) the statement caused actual or special damages.’ ” Green at 430-431 , quoting Colquhoun v. Webber, 684 A.2d 405, 409 (Me. 1996). “ ‘As a general rule, wrongfully recording an unfounded claim to the property of another constitutes slander of title.’ ” Cuspide Properties, Ltd. v. Earl Mechanical Servs., 2015-Ohio-5019, ¶ 37 (6th

2015To prevail on a claim of slander of title, the claimant must prove: “ ‘(1) there was a publication of a slanderous statement disparaging claimant’s title; (2) the statement was false; (3) the statement was made with malice or made with a reckless disregard of falsity; and (4) the statement caused actual or special damages.’ ” Green at 430-431 , quoting Colquhoun v. Webber, 684 A.2d 405, 409 (Me.1996). {¶37} We note that there was no evidence presented at trial concerning the mechanic’s lien Dennis filed, or that the lien was filed with a malicious intent or with a reckless disregard of falsity

34
Green v. Lemarrgreen
ohioctapp · 2000 · cited in 5 Ohio opinions naming this issue, 2007–2024
2 sentences

2024“Generally, slander of title to real estate involves the wrongful recording of an unfounded claim, such as a mechanic’s lien, to the property of another.” Id., citing Green at 433 .

2019“Generally, slander of title to real estate involves the wrongful recording of an unfounded claim, such as a mechanic's lien, to the property of another.” Id., citing Green at 433 .

15
McClure v. Fischer Attached Homesgreen
ohctcomplclermo · 2007 · cited in 2 Ohio opinions naming this issue, 2015–2024
2 sentences

2024To prevail on a slander of title claim, “a claimant must prove ‘(1) there was a publication of a slanderous statement disparaging claimant's title; (2) the statement was false; (3) the statement was made with malice or made with reckless disregard of its falsity; and (4) the statement caused actual or special damages.’ ” Green at 430-431 , quoting Colquhoun v. Webber, 684 A.2d 405, 409 (Me. 1996). “ ‘As a general rule, wrongfully recording an unfounded claim to the property of another constitutes slander of title.’ ” Cuspide Properties, Ltd. v. Earl Mechanical Servs., 2015-Ohio-5019, ¶ 37 (6th

2015“As a general rule, wrongfully recording an unfounded claim to the property of another constitutes slander of title.” McClure, 145 Ohio Misc.2d 38 , 2007-Ohio-7259, at ¶ 21 . {¶ 38} We find a slanderous statement disparaging Cuspide’s title was published when the mechanic’s lien was recorded by appellant.

12
Cuspide Properties, Ltd. v. Earl Mechanical Servs.green
ohioctapp · 2015 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024To prevail on a slander of title claim, “a claimant must prove ‘(1) there was a publication of a slanderous statement disparaging claimant's title; (2) the statement was false; (3) the statement was made with malice or made with reckless disregard of its falsity; and (4) the statement caused actual or special damages.’ ” Green at 430-431 , quoting Colquhoun v. Webber, 684 A.2d 405, 409 (Me. 1996). “ ‘As a general rule, wrongfully recording an unfounded claim to the property of another constitutes slander of title.’ ” Cuspide Properties, Ltd. v. Earl Mechanical Servs., 2015-Ohio-5019, ¶ 37 (6th

11
Prater v. Dashkovsky, 07ap-389 (12-18-2007)green
ohioctapp · 2007 · cited in 1 Ohio opinions naming this issue, 2024–2024
1 sentence

2024To prevail on a slander of title claim, “a claimant must prove ‘(1) there was a publication of a slanderous statement disparaging claimant's title; (2) the statement was false; (3) the statement was made with malice or made with reckless disregard of its falsity; and (4) the statement caused actual or special damages.’ ” Green at 430-431 , quoting Colquhoun v. Webber, 684 A.2d 405, 409 (Me. 1996). “ ‘As a general rule, wrongfully recording an unfounded claim to the property of another constitutes slander of title.’ ” Cuspide Properties, Ltd. v. Earl Mechanical Servs., 2015-Ohio-5019, ¶ 37 (6th

11
O'Loughlin v. Ottawa St. Condominium Assn.green
ohioctapp · 2018 · cited in 1 Ohio opinions naming this issue, 2019–2019
1 sentence

2019Lucas No. L-16-1128, 2018-Ohio-327, ¶ 27 (Slander of title occurs when there is a “wrongful[] recording [of] an unfounded claim.”). {¶37} The complaint did not contain any allegations that Bank of America wrongfully recorded the mortgage on March 25, 2010.

11
State ex rel. Plain Dealer Publishing Co. v. Geauga County Court of Common Pleasgreen
ohio · 2000 · cited in 1 Ohio opinions naming this issue, 2006–2006
2 sentences

2006As cogently observed by the Plain Dealer, Judge Floyd’s granting closure because there was no opposition, when combined with the juvenile court’s general failure to give notice concerning closure motions and hearings on those motions, effectively precluded the general public from most juvenile court proceedings, resulting in an unfounded presumption of closed juvenile proceedings. {¶ 35} This result fails to accord sufficient weight to the “many legitimate interests [that] favor public access to [juvenile delinquency] proceedings.” Plain Dealer, 90 Ohio St.3d at 84, 734 N.E.2d 1214 .

2006As cogently observed by the Plain Dealer, Judge Floyd’s granting closure because there was no opposition, when combined with the juvenile court’s general failure to give notice concerning closure motions and hearings on those motions, effectively precluded the general public from most juvenile court proceedings, resulting in an unfounded presumption of closed juvenile proceedings. {¶ 35} This result fails to accord sufficient weight to the “many legitimate interests [that] favor public access to [juvenile delinquency] proceedings.” Plain Dealer, 90 Ohio St.3d at 84, 734 N.E.2d 1214 .

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 (5)

CaseCitedYears
TXO Production Corp. v. Alliance Resources Corp. green
wva · 1992
2 sentences

2023Corp. v. Alliance Resources Corp., 187 W.Va. 457, 467 , 419 S.E.2d 870 (1992).

2000You know there is a cloud on the title * * *.’ “As a general rule, courts have found that wrongfully recording an unfounded claim to the property of another is actionable as slander of title. * * * This is *434 so provided that the other elements for slander of title, namely malice and special damages, are present.” 187 W.Va. at 466-67 , 419 S.E.2d at 879-880 .

22000–2023
Metzler v. Fifth Third Bank green
ohioctapp · 2017
1 sentence

2024Franklin No. 16AP-638, 2017-Ohio-7088, ¶ 14 .

12024–2024
WWSD, L.L.C. v. Woods green
ohioctapp · 2023
1 sentence

2023“Documents filed against real property impact title by placing a cloud on the title.” Id. “ ‘As a general rule, courts have found that wrongfully recording an unfounded claim to the property of another is actionable as slander of title. * * * This is so provided that the other elements for slander of title, namely malice and special damages, are present.’ ” (Omission sic.) Green at 433-434 , quoting TXO Prod.

12023–2023
State v. Dansby-East green
ohioctapp · 2019
1 sentence

2020Cuyahoga No. 107418, 2019-Ohio-2218 , and this court rejected the unfounded claim that a heightened standard for the imposition of consecutive sentences was created in Peak.

12020–2020
Buehrer v. Provident Mutual Life Ins. green
· 1931
1 sentence

2017Id.

12017–2017

Where else courts name it

NC 47 (1978–2026) NY 15 (1843–2012) OH 14 (2000–2024) IL 13 (1888–2023) CA 11 (1890–2016) NM 11 (1969–2024) MD 10 (1871–2016) MO 9 (1956–2021) VA 7 (1925–2025) MI 6 (1881–2025) CO 5 (1994–2025) SC 5 (1995–2018) PA 4 (1877–2019) GA 3 (1947–1991) IN 3 (1899–2001) AZ 3 (1967–1971) AL 3 (1886–1982) IA 3 (1908–1996) OK 2 (1976–2018) TN 2 (1860–1860) OR 2 (1896–1960) KY 2 (1877–1914) KS 2 (1922–2021) WV 2 (1892–1946)

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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