12 Ohio opinions name it 1 courts 1994–2026 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 |
|---|---|---|
Molnar v. Greengreen2 sentences2026While Anderson, 2012-Ohio-5711, sets forth separate and distinct definitions of willful, wanton and reckless, the trial court lumped all those standards together without any analysis of how the officer’s conduct met any of those definitions. “‘Without any explanation by the trial court as to the basis on which statutory immunity did not apply to the parties, this court cannot adequately analyze the trial court’s order in a reviewing capacity.’” Hall, 2024-Ohio-5540, at ¶ 11 (9th Dist.), quoting Molnar v. City of Green, 2018-Ohio-1168, ¶ 6 (9th Dist.). 2026While Anderson, 2012-Ohio-5711 , sets forth separate and distinct definitions of willful, wanton and reckless, the trial court lumped all those standards together without any analysis of how the officer’s conduct met any of those definitions. “‘Without any explanation by the trial court as to the basis on which statutory immunity did not apply to the parties, this court cannot adequately analyze the trial court’s order in a reviewing capacity.’” Hall, 2024-Ohio-5540, at ¶ 11 (9th Dist.), quoting Molnar v. City of Green, 2018-Ohio-1168, ¶ 6 (9th Dist.). | 1 | 1 |
State v. Milesgreen1 sentence2026See State v. Miles, 2021-Ohio-1029, ¶ 7, 14-15 (5th Dist.) (a dog sniff that began five minutes into the stop and finished eight minutes into the stop did not prolong the stop where the officer stated a standard stop takes him approximately 15 minutes); State v. Green, 2016-Ohio-4810, ¶ 19-20 (7th Dist.) (a dog did not arrive on scene until ten minutes after the stop was initiated and eight minutes after the ticket was issued and this unconstitutionally prolonged the stop); State v. Heath, 2023-Ohio-2647 , ¶ 13, 25 (11th Dist.) (reasonable suspicion was not necessary because the dog sniff occu | 1 | 1 |
State v. Hallgreen2 sentences2026While Anderson, 2012-Ohio-5711, sets forth separate and distinct definitions of willful, wanton and reckless, the trial court lumped all those standards together without any analysis of how the officer’s conduct met any of those definitions. “‘Without any explanation by the trial court as to the basis on which statutory immunity did not apply to the parties, this court cannot adequately analyze the trial court’s order in a reviewing capacity.’” Hall, 2024-Ohio-5540, at ¶ 11 (9th Dist.), quoting Molnar v. City of Green, 2018-Ohio-1168, ¶ 6 (9th Dist.). 2026While Anderson, 2012-Ohio-5711 , sets forth separate and distinct definitions of willful, wanton and reckless, the trial court lumped all those standards together without any analysis of how the officer’s conduct met any of those definitions. “‘Without any explanation by the trial court as to the basis on which statutory immunity did not apply to the parties, this court cannot adequately analyze the trial court’s order in a reviewing capacity.’” Hall, 2024-Ohio-5540, at ¶ 11 (9th Dist.), quoting Molnar v. City of Green, 2018-Ohio-1168, ¶ 6 (9th Dist.). | 1 | 1 |
State v. Greengreen1 sentence2026See State v. Miles, 2021-Ohio-1029, ¶ 7, 14-15 (5th Dist.) (a dog sniff that began five minutes into the stop and finished eight minutes into the stop did not prolong the stop where the officer stated a standard stop takes him approximately 15 minutes); State v. Green, 2016-Ohio-4810, ¶ 19-20 (7th Dist.) (a dog did not arrive on scene until ten minutes after the stop was initiated and eight minutes after the ticket was issued and this unconstitutionally prolonged the stop); State v. Heath, 2023-Ohio-2647 , ¶ 13, 25 (11th Dist.) (reasonable suspicion was not necessary because the dog sniff occu | 1 | 1 |
Selvy v. Morrisongreen2 sentences2009See Selvy v. Morrison (2008), 292 Ga.App. 702, 706 , 665 S.E.2d 401 (concluding that an officer’s derogatory remarks and use of profanity were insufficient to exempt the officer from immunity and noting that “proof of ill will, unless * * * combined with the intent to do something wrongful or illegal,” does not substantiate a finding of malice); see also Tittle v. Corso (2002), 256 Ga.App. 859, 863 , 569 S.E.2d 873 (concluding that an officer’s use of profanity, threats, and physical force did not demonstrate a deliberate intent to commit a wrongful act as required to prove malice and abolish 2009See Selvy v. Morrison (2008), 292 Ga.App. 702, 706 , 665 S.E.2d 401 (concluding that an officer’s derogatory remarks and use of profanity were insufficient to exempt the officer from immunity and noting that “proof of ill will, unless * * * combined with the intent to do something wrongful or illegal,” does not substantiate a finding of malice); see also Tittle v. Corso (2002), 256 Ga.App. 859, 863 , 569 S.E.2d 873 (concluding that an officer’s use of profanity, threats, and physical force did not demonstrate a deliberate intent to commit a wrongful act as required to prove malice and abolish | 1 | 1 |
Tittle v. Corsogreen2 sentences2009See Selvy v. Morrison (2008), 292 Ga.App. 702, 706 , 665 S.E.2d 401 (concluding that an officer’s derogatory remarks and use of profanity were insufficient to exempt the officer from immunity and noting that “proof of ill will, unless * * * combined with the intent to do something wrongful or illegal,” does not substantiate a finding of malice); see also Tittle v. Corso (2002), 256 Ga.App. 859, 863 , 569 S.E.2d 873 (concluding that an officer’s use of profanity, threats, and physical force did not demonstrate a deliberate intent to commit a wrongful act as required to prove malice and abolish 2009See Selvy v. Morrison (2008), 292 Ga.App. 702, 706 , 665 S.E.2d 401 (concluding that an officer’s derogatory remarks and use of profanity were insufficient to exempt the officer from immunity and noting that “proof of ill will, unless * * * combined with the intent to do something wrongful or illegal,” does not substantiate a finding of malice); see also Tittle v. Corso (2002), 256 Ga.App. 859, 863 , 569 S.E.2d 873 (concluding that an officer’s use of profanity, threats, and physical force did not demonstrate a deliberate intent to commit a wrongful act as required to prove malice and abolish | 1 | 1 |
State v. Thompsongreen2 sentences1994See State v. Thompson (1987), 33 Ohio St.3d 1 , 514 N.E.2d 407 . 1994See State v. Thompson (1987), 33 Ohio St.3d 1 , 514 N.E.2d 407 . | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Anderson v. City of Massillon
green
2 sentences2026Relevant to this case, R.C. 2744.03(A)(6)(a)/(b) states that an employee of a political subdivision is immune from liability unless his or her actions “were manifestly outside the scope of the employee’s employment or official responsibilities” or if the “employee’s acts . . . were with malicious purpose, in bad faith, or in a wanton or reckless manner[.]” Ms. Johnson argued in her 6 opposition to the Officer’s motion for summary judgment that the Officers “were outside the scope of their employment in technical violation of their training” when they were at her apartment and that they engaged 2026Relevant to this case, R.C. 2744.03(A)(6)(a)/(b) states that an employee of a political subdivision is immune from liability unless his or her actions “were manifestly outside the scope of the employee’s employment or official responsibilities” or if the “employee’s acts . . . were with malicious purpose, in bad faith, or in a wanton or reckless manner[.]” Ms. Johnson argued in her 6 opposition to the Officer’s motion for summary judgment that the Officers “were outside the scope of their employment in technical violation of their training” when they were at her apartment and that they engaged | 1 | 2026–2026 |
State v. Honey
green
1 sentence2024Hamilton No. C-230239, 2024-Ohio-834, ¶ 22 . | 1 | 2024–2024 |
Bryan Frodge v. City of Newport
green
1 sentence2018The trial court granted the officer immunity, and the plaintiffs appealed. {¶65} On appeal, the plaintiffs argued that “their assertion of the affirmative defense of self-defense should have precluded [the officer] from arresting them” and pointed out that the officer “did not ask them their side of the story and did not consider the damage to their car.” Id. at 528 . | 1 | 2018–2018 |
Cleveland v. Cord
green
1 sentence2013No. 96312, 2011-Ohio-4262, ¶ 19 . {¶34} Insofar as Davis contends she was unable to subpoena the officer who reviewed the alleged speeding infraction to challenge the radar device, we find that Davis did not attempt to subpoena the officer to the hearing on the notice of liability. | 1 | 2013–2013 |
State Ex Rel. Gordon v. Barthalow
green
1 sentence2011In general, “ ‘[o]ffices are held, in this country, neither by grant nor contract, nor has any person a vested interest or private right of property in them.’ ” Id., quoting Steubenville v. Culp (1882), 38 Ohio St. 18 , 23. “ ‘[I]f the office [is] created by the Legislature, it may, in the absence of express constitutional restriction, be abolished or suspended; and yet the officer can not claim compensation, for the loss of his office. | 1 | 2011–2011 |
State v. Treesh
green
1 sentence2008Further cross-examination on the subject did not cause the officer to waiver in his testimony that also corroborated Robison's testimony. {¶ 19} To the extent defendant contends his trial counsel was ineffective in failing to call his mother to be a witness on his behalf, the decision "falls within the rubric of trial strategy and will not be second-guessed by a reviewing court." State v. Leonard , 104 Ohio St.3d 54 , 2004-Ohio-6235 , at ¶ 143 , quoting State v. Treesh (2001), 90 Ohio St.3d 460 , 490 . | 1 | 2008–2008 |
State v. Leonard
green
1 sentence2008Further cross-examination on the subject did not cause the officer to waiver in his testimony that also corroborated Robison's testimony. {¶ 19} To the extent defendant contends his trial counsel was ineffective in failing to call his mother to be a witness on his behalf, the decision "falls within the rubric of trial strategy and will not be second-guessed by a reviewing court." State v. Leonard , 104 Ohio St.3d 54 , 2004-Ohio-6235 , at ¶ 143 , quoting State v. Treesh (2001), 90 Ohio St.3d 460 , 490 . | 1 | 2008–2008 |
State v. Evans
green
1 sentence2004State v. Evans (1993), 67 Ohio St.3d 405 . | 1 | 2004–2004 |
City of Dayton v. Erickson
green
1 sentence1998Thus, we have a case where three clear traffic violations were observed by the officer and under the rule announced by the Supreme Court in Dayton v. Erickson (1996), 76 Ohio St.3d 3 , any one of these traffic violations, no matter how minor, justifies a traffic stop even if the officer believed that he might have a case of alcohol impairment to investigate. | 1 | 1998–1998 |
Terry v. Ohio
green
2 sentences1995Terry, supra, 392 U.S. at 21-22 , 88 S.Ct. at 1879-1880 , 20 L.Ed.2d at 906 . 1995Terry, supra, 392 U.S. at 21-22 , 88 S.Ct. at 1879-1880 , 20 L.Ed.2d at 906 . | 1 | 1995–1995 |
State v. Bishop
green
2 sentences1995As this court pointed out in Bishop, supra, 95 Ohio App.3d at 622 , 643 N.E.2d at 172 , “[i]f a police officer follows a motorist long enough, eventually the officer will observe some minor traffic violation which the officer can claim justifies an investigative stop.” If the Fourth Amendment is to have meaning, the trial court must “evaluate the reasonableness of a particular search or seizure in light of the particular circumstances” in which the search or seizure occurred. 1995As this court pointed out in Bishop, supra, 95 Ohio App.3d at 622 , 643 N.E.2d at 172 , “[i]f a police officer follows a motorist long enough, eventually the officer will observe some minor traffic violation which the officer can claim justifies an investigative stop.” If the Fourth Amendment is to have meaning, the trial court must “evaluate the reasonableness of a particular search or seizure in light of the particular circumstances” in which the search or seizure occurred. | 1 | 1995–1995 |
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.