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13 Ohio opinions name it 3 courts 2006–2025 6 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 |
|---|---|---|
United States v. Noblesgreen2 sentences2025See Nobles at 233-234, 236-240 (regarding the privilege against self- incrimination and the attorney work-product doctrine, but not the attorney-client privilege); Knepper at paragraph two of the syllabus (explaining that the purpose of a subscribing witness to a will is to preserve and provide evidence that the document was validly executed, and thus when an attorney acts as a subscribing witness, the attorney- client privilege cannot attach to evidence regarding the valid execution of that will); Baird at 200 (same); Haley at 328 , citing Baird. {¶ 23} Although the precise waiver argument he 2021United States v. Nobles, 422 U.S. 225, 236 , 95 S.Ct. 2160 , 45 L.Ed.2d 141 (1975). | 3 | 4 |
State ex rel. Greater Cleveland Regional Transit Authority v. Guzzogreen2 sentences2023Greater Cleveland Regional Transit Auth. v. Guzzo, 6 Ohio St.3d 270, 271 (1983). 2013Greater Cleveland Regional Transit Auth. v. Guzzo, 6 Ohio St.3d 270, 271 (1983). | 2 | 2 |
Squire, Sanders & Dempsey, L.L.P. v. Givaudan Flavors Corp.green2 sentences2021See Squire, Sanders & Dempsey, L.L.P., 127 Ohio St.3d 161 , 2010-Ohio-4469 , 937 N.E.2d 533, at ¶ 54 . {¶ 17} The United States Supreme Court has also held that the attorney- work-product doctrine applies in criminal cases. 2021See Squire, Sanders & Dempsey, L.L.P., 127 Ohio St.3d 161 , 2010-Ohio-4469 , 937 N.E.2d 533, at ¶ 54 . {¶ 17} The United States Supreme Court has also held that the attorney- work-product doctrine applies in criminal cases. | 1 | 3 |
Burnham v. Cleveland Clinic (Slip Opinion)green2 sentences2022See, e.g., Burnham v. Cleveland Clinic, 151 Ohio St.3d 356 , 2016-Ohio-8000, ¶ 2 (lead opinion) (remarking that, as opposed to attorney work-product, "an order requiring the production of information protected by the attorney-client privilege causes harm and prejudice that inherently cannot be meaningfully or effectively remedied by a later appeal"); In re Grand Jury Proceeding of Doe, 150 Ohio St.3d 398 , 2016-Ohio-8001, ¶ 22 ("When a party is compelled to produce material protected by the attorney-client privilege, harm extends beyond the actual case being litigated and causes the loss of a 2020Id. at ¶ 15. {¶ 43} “In Ohio, protection for an attorney’s work product is codified in Civ.R. 26, which notably recognizes work product as separate from privileged matters.” Burnham v. Cleveland Clinic, 151 Ohio St.3d 356 , 2016-Ohio-8000 , 89 N.E.3d 536 , ¶ 18. | 1 | 2 |
Welsh-Huggins v. Jefferson Cty. Prosecutor's Office (Slip Opinion)green1 sentence2025The propriety of the redactions/withholdings not discussed below was established by the contents of the records themselves, the affidavit testimony Cleveland produced in support of those redactions/withholdings, or both. 2 Welsh-Huggins, 2020-Ohio-5371, ¶¶ 30, 35, 50, 53 . {¶37} Several email chains were improperly redacted: those that reflected Cleveland’s lawyers’ interaction with its public relations staff concerning responses to 2 It should be noted that most of Cleveland’s redactions and withholdings were based on the attorney work product doctrine. | 1 | 1 |
Baird v. Detrickgreen1 sentence2025See Nobles at 233-234, 236-240 (regarding the privilege against self- incrimination and the attorney work-product doctrine, but not the attorney-client privilege); Knepper at paragraph two of the syllabus (explaining that the purpose of a subscribing witness to a will is to preserve and provide evidence that the document was validly executed, and thus when an attorney acts as a subscribing witness, the attorney- client privilege cannot attach to evidence regarding the valid execution of that will); Baird at 200 (same); Haley at 328 , citing Baird. {¶ 23} Although the precise waiver argument he | 1 | 1 |
In Re Grand Jury Proceeding of John Doegreen2 sentences2022See, e.g., Burnham v. Cleveland Clinic, 151 Ohio St.3d 356 , 2016-Ohio-8000, ¶ 2 (lead opinion) (remarking that, as opposed to attorney work-product, "an order requiring the production of information protected by the attorney-client privilege causes harm and prejudice that inherently cannot be meaningfully or effectively remedied by a later appeal"); In re Grand Jury Proceeding of Doe, 150 Ohio St.3d 398 , 2016-Ohio-8001, ¶ 22 ("When a party is compelled to produce material protected by the attorney-client privilege, harm extends beyond the actual case being litigated and causes the loss of a 2022See, e.g., Burnham v. Cleveland Clinic, 151 Ohio St.3d 356 , 2016-Ohio-8000, ¶ 2 (lead opinion) (remarking that, as opposed to attorney work-product, "an order requiring the production of information protected by the attorney-client privilege causes harm and prejudice that inherently cannot be meaningfully or effectively remedied by a later appeal"); In re Grand Jury Proceeding of Doe, 150 Ohio St.3d 398 , 2016-Ohio-8001, ¶ 22 ("When a party is compelled to produce material protected by the attorney-client privilege, harm extends beyond the actual case being litigated and causes the loss of a | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Smith v. Chen
green
2 sentences2017The court accepted the Clinic’s discretionary appeal to resolve whether an order compelling the production of documents allegedly protected by the attorney-client privilege is a final, appealable order under R.C. 2505.02(B)(4). [The court] also accepted review to clarify our holding regarding privilege, the attorney work-product doctrine, and R.C. 2505.02(B)(4)(b) in Smith v. Chen, 142 Ohio St.3d 411 , 2015-Ohio-1480 , 31 N.E.3d 633 . 2017The court accepted the Clinic’s discretionary appeal to resolve whether an order compelling the production of documents allegedly protected by the attorney-client privilege is a final, appealable order under R.C. 2505.02(B)(4). [The court] also accepted review to clarify our holding regarding privilege, the attorney work-product doctrine, and R.C. 2505.02(B)(4)(b) in Smith v. Chen, 142 Ohio St.3d 411 , 2015-Ohio-1480 , 31 N.E.3d 633 . | 2 | 2016–2017 |
State ex rel. V.K.B. v. Smith
neutral
2 sentences2022V.K.B. v. Smith, 138 Ohio St.3d 84 , 2013-Ohio-5477 , 3 N.E.3d 1184, ¶ 10 . {¶5} OSU asserts the requested records are exempt in their entirety by application of 1) the attorney-client privilege, 2) the trial preparation records exemption, 3) the attorney work-product doctrine, 4) the non-testifying consultant privilege, and 5) Rule 1.6 of the Ohio Rules of Professional Conduct. 2022V.K.B. v. Smith, 138 Ohio St.3d 84 , 2013-Ohio-5477 , 3 N.E.3d 1184, ¶ 10 . {¶5} OSU asserts the requested records are exempt in their entirety by application of 1) the attorney-client privilege, 2) the trial preparation records exemption, 3) the attorney work-product doctrine, 4) the non-testifying consultant privilege, and 5) Rule 1.6 of the Ohio Rules of Professional Conduct. | 1 | 2022–2022 |
Westfield Insurance v. Galatis
green
2 sentences2016Co. v. Galatis, 100 Ohio St.3d 216 , 2003- Ohio-5849, 797 N.E.2d 1256 , paragraph one of the syllabus, the court’s opinion doubles down and creates new law wherein a discovery order that is alleged to breach the confidentiality guaranteed by the attorney-client privilege satisfies R.C. 2505.02(B)(4)(b) and is a final, appealable order, [but] [o]ther discovery protections that do not involve common law, constitutional, or statutory guarantees of confidentiality, such as the attorney work-product doctrine, may require a showing under R.C. 2505.02(B)(4)(b) beyond the mere statement that the matte 2016Co. v. Galatis, 100 Ohio St.3d 216 , 2003- Ohio-5849, 797 N.E.2d 1256 , paragraph one of the syllabus, the court’s opinion doubles down and creates new law wherein a discovery order that is alleged to breach the confidentiality guaranteed by the attorney-client privilege satisfies R.C. 2505.02(B)(4)(b) and is a final, appealable order, [but] [o]ther discovery protections that do not involve common law, constitutional, or statutory guarantees of confidentiality, such as the attorney work-product doctrine, may require a showing under R.C. 2505.02(B)(4)(b) beyond the mere statement that the matte | 1 | 2016–2016 |
Smith v. Chen
neutral
2 sentences2016Id. at ¶ 11. {¶ 14} We initially accepted discretionary review on whether an order compelling production of surveillance video created only for impeachment purposes violates the attorney work-product doctrine of Civ.R. 26(B)(3). 138 Ohio St.3d 1447 , 2014-Ohio-1182 , 5 N.E.3d 666 . 2016Id. at ¶ 11. {¶ 14} We initially accepted discretionary review on whether an order compelling production of surveillance video created only for impeachment purposes violates the attorney work-product doctrine of Civ.R. 26(B)(3). 138 Ohio St.3d 1447 , 2014-Ohio-1182 , 5 N.E.3d 666 . | 1 | 2016–2016 |
State v. Springer
neutral
2 sentences2016Id. at ¶ 11. {¶ 14} We initially accepted discretionary review on whether an order compelling production of surveillance video created only for impeachment purposes violates the attorney work-product doctrine of Civ.R. 26(B)(3). 138 Ohio St.3d 1447 , 2014-Ohio-1182 , 5 N.E.3d 666 . 2016Id. at ¶ 11. {¶ 14} We initially accepted discretionary review on whether an order compelling production of surveillance video created only for impeachment purposes violates the attorney work-product doctrine of Civ.R. 26(B)(3). 138 Ohio St.3d 1447 , 2014-Ohio-1182 , 5 N.E.3d 666 . | 1 | 2016–2016 |
Hope Academy Broadway Campus v. White Hat Mgt., L.L.C.
green
2 sentences2016Id. at ¶ 11. {¶ 14} We initially accepted discretionary review on whether an order compelling production of surveillance video created only for impeachment purposes violates the attorney work-product doctrine of Civ.R. 26(B)(3). 138 Ohio St.3d 1447 , 2014-Ohio-1182 , 5 N.E.3d 666 . 2016Id. at ¶ 11. {¶ 14} We initially accepted discretionary review on whether an order compelling production of surveillance video created only for impeachment purposes violates the attorney work-product doctrine of Civ.R. 26(B)(3). 138 Ohio St.3d 1447 , 2014-Ohio-1182 , 5 N.E.3d 666 . | 1 | 2016–2016 |
Manofsky v. Goodyear Tire & Rubber Co.
green
2 sentences2012Manofsky v. Goodyear Tire & Rubber Co., 69 Ohio App.3d 663, 668 , 591 N.E.2d 752 (9th Dist.1990). 2012Manofsky v. Goodyear Tire & Rubber Co., 69 Ohio App.3d 663, 668 , 591 N.E.2d 752 (9th Dist.1990). | 1 | 2012–2012 |
Hickman v. Taylor
green
2 sentences2006Co. v. Tracy, 73 Ohio St.3d 371, 1995-Ohio-296 , 653 N.E.2d 220 . {¶ 10} The estate also cites Hickman v. Taylor, 329 U.S. 495 , 67 S.Ct. 385 , 91 L.Ed. 451 , in which the Supreme Court first enumerated the attorney work-product doctrine. 2006Co. v. Tracy, 73 Ohio St.3d 371, 1995-Ohio-296 , 653 N.E.2d 220 . {¶ 10} The estate also cites Hickman v. Taylor, 329 U.S. 495 , 67 S.Ct. 385 , 91 L.Ed. 451 , in which the Supreme Court first enumerated the attorney work-product doctrine. | 1 | 2006–2006 |
Community Mutual Insurance v. Tracy
green
2 sentences2006Co. v. Tracy, 73 Ohio St.3d 371, 1995-Ohio-296 , 653 N.E.2d 220 . {¶ 10} The estate also cites Hickman v. Taylor, 329 U.S. 495 , 67 S.Ct. 385 , 91 L.Ed. 451 , in which the Supreme Court first enumerated the attorney work-product doctrine. 2006Co. v. Tracy, 73 Ohio St.3d 371, 1995-Ohio-296 , 653 N.E.2d 220 . {¶ 10} The estate also cites Hickman v. Taylor, 329 U.S. 495 , 67 S.Ct. 385 , 91 L.Ed. 451 , in which the Supreme Court first enumerated the attorney work-product doctrine. | 1 | 2006–2006 |
Community Mut. Ins. Co. v. Tracy
neutral
1 sentence2006Co. v. Tracy, 73 Ohio St.3d 371, 1995-Ohio-296 , 653 N.E.2d 220 . {¶ 10} The estate also cites Hickman v. Taylor, 329 U.S. 495 , 67 S.Ct. 385 , 91 L.Ed. 451 , in which the Supreme Court first enumerated the attorney work-product doctrine. | 1 | 2006–2006 |
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.