11 Ohio opinions name it 1 courts 2000–2026 7 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 |
|---|---|---|
Gray Panthers v. Richard S. Schweiker, Secretary of the Department of Health and Human Servicesgreen2 sentences2026Hearings may take many forms, including a ‘formal,’ trial-type proceeding, an ‘informal discuss(ion)’ . . ., or a ‘paper hearing,’ without any opportunity for oral exchange.” Costin at ¶ 21 , quoting Liese v. Kent State Univ., 2004-Ohio-5322, ¶ 38, fn. 6 (11th Dist.), quoting Gray Panthers v. Schweiker, 652 F.2d 146, 148, fn. 3 (D.C.Cir. 1980); see also Nemec v. Morledge, 2021-Ohio-3361 , ¶ 18 (8th Dist.), citing Marks at ¶ 29 , quoting Liese. 2025Hearings may take many forms, including a ‘formal,’ trial-type proceeding, an ‘informal discuss(ion)’ . . ., or a ‘paper hearing,’ without any opportunity for oral exchange.” (Brackets in original.) Id., quoting Liese v. Kent State Univ., 2004-Ohio-5322, ¶ 38, fn. 6 (11th Dist.), quoting Gray Panthers v. Schweiker, 652 F.2d 146, 148, fn.3 (C.A.D.C. 1980). | 2 | 2 |
Liese v. Kent State Univ., Unpublished Decision (9-30-2004)green2 sentences2026Hearings may take many forms, including a ‘formal,’ trial-type proceeding, an ‘informal discuss(ion)’ . . ., or a ‘paper hearing,’ without any opportunity for oral exchange.” Costin at ¶ 21 , quoting Liese v. Kent State Univ., 2004-Ohio-5322, ¶ 38, fn. 6 (11th Dist.), quoting Gray Panthers v. Schweiker, 652 F.2d 146, 148, fn. 3 (D.C.Cir. 1980); see also Nemec v. Morledge, 2021-Ohio-3361 , ¶ 18 (8th Dist.), citing Marks at ¶ 29 , quoting Liese. 2025Hearings may take many forms, including a ‘formal,’ trial-type proceeding, an ‘informal discuss(ion)’ . . ., or a ‘paper hearing,’ without any opportunity for oral exchange.” (Brackets in original.) Id., quoting Liese v. Kent State Univ., 2004-Ohio-5322, ¶ 38, fn. 6 (11th Dist.), quoting Gray Panthers v. Schweiker, 652 F.2d 146, 148, fn.3 (C.A.D.C. 1980). | 2 | 2 |
State v. Bostickgreen2 sentences2026But absent such specificity, “the decision whether to hold an oral evidentiary hearing is left to the discretion of the trial court.” See State v. Bostick, Slip Opinion No. 2025-Ohio-5559, ¶ 19 . 2026State v. Bostick, 2025-Ohio-5559, ¶ 20 . - 20 - Butler CA2025-05-041 {¶ 67} "The doctrine of res judicata provides that a final judgment of conviction bars a convicted defendant who was represented by counsel from raising and litigating in any proceeding[,] except an appeal from that judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial, which resulted in that judgment of conviction . . . ." State v. Hagens, 2025-Ohio-4989, ¶ 21 (12th Dist.), citing State v. Wagers, 2012-Ohio-2258 , ¶ 10 (12th Dist.). | 1 | 3 |
State v. Hagensgreen1 sentence2026State v. Bostick, 2025-Ohio-5559, ¶ 20 . - 20 - Butler CA2025-05-041 {¶ 67} "The doctrine of res judicata provides that a final judgment of conviction bars a convicted defendant who was represented by counsel from raising and litigating in any proceeding[,] except an appeal from that judgment, any defense or any claimed lack of due process that was raised or could have been raised by the defendant at the trial, which resulted in that judgment of conviction . . . ." State v. Hagens, 2025-Ohio-4989, ¶ 21 (12th Dist.), citing State v. Wagers, 2012-Ohio-2258 , ¶ 10 (12th Dist.). | 1 | 1 |
Dayton Lodge, L.L.C. v. Hoffmangreen1 sentence2026Compare, e.g., Fifth Third, 2013-Ohio-5755, at ¶ 54 (2d Dist.) (requiring oral evidentiary hearing because 8 The Domestic Relations Division has no time-for-filing rule of its own. 9 See Baker, Introduction to English Legal History, 112 (5th Ed. 2019); Bruhl, Law and Equity on Appeal, 124 Colum.L.Rev. 2307, 2335-2336 (2024). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Pruszynski v. Reeves
green
2 sentences2017However, a review of the record shows that the trial court did not hold an oral evidentiary hearing nor order a date certain for the submission of evidentiary materials. {¶ 29} The Supreme Court of Ohio has specifically held that "a trial court must set a date certain for an evidentiary hearing before ruling on an R.C. 1343.03(C) motion for prejudgment interest." Pruszynski v. Reeves , 117 Ohio St.3d 92 , 2008-Ohio-510 , 881 N.E.2d 1230 , ¶ 1. 2017However, a review of the record shows that the trial court did not hold an oral evidentiary hearing nor order a date certain for the submission of evidentiary materials. {¶ 29} The Supreme Court of Ohio has specifically held that "a trial court must set a date certain for an evidentiary hearing before ruling on an R.C. 1343.03(C) motion for prejudgment interest." Pruszynski v. Reeves , 117 Ohio St.3d 92 , 2008-Ohio-510 , 881 N.E.2d 1230 , ¶ 1. | 2 | 2013–2017 |
Paynter v. Paynter, Unpublished Decision (12-23-2003)
neutral
1 sentence2024Id. at ¶ 11; Paynter v. Paynter, Muskingum App. No. CT2003-0024, 2003-Ohio-7101 .” Id. at ¶ 18-19. {¶75} Since the evidence submitted with the parties’ erroneously labeled motions for summary judgment, including affidavits, depositions, and exhibits, “sufficiently argued the parties’ disparate positions,” the trial court was not required to hold an oral evidentiary hearing. | 1 | 2024–2024 |
King v. Mohre
green
2 sentences2023The trial court, however, has the discretion to determine the nature of the evidentiary hearing to be held, as it is in the best position to select the kind of evidence necessary to make the findings required by R.C. 1343.03(C) and determine whether an award of prejudgment interest is proper. {¶122} “Having conducted case-management conferences, pretrials, settlement conferences, and the trial, a court in some instances may decide that presentation of evidence by affidavits, depositions, and other documents is sufficient; at other times, the trial court may decide that an oral evidentiary hear 2023The trial court, however, has the discretion to determine the nature of the evidentiary hearing to be held, as it is in the best position to select the kind of evidence necessary to make the findings required by R.C. 1343.03(C) and determine whether an award of prejudgment interest is proper. {¶122} “Having conducted case-management conferences, pretrials, settlement conferences, and the trial, a court in some instances may decide that presentation of evidence by affidavits, depositions, and other documents is sufficient; at other times, the trial court may decide that an oral evidentiary hear | 1 | 2023–2023 |
State v. Adams
green
2 sentences2019Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983), quoting State v. Adams, 62 Ohio St.2d 151, 157 , 404 N.E.2d 144 (1980). {¶ 12} The trial court did not conduct a separate oral evidentiary hearing on the common law motion to vacate default judgment for lack of personal jurisdiction, instead relying on the entire record, including, without limitation, the January 8, 2010 evidentiary hearing on damages. 2019Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983), quoting State v. Adams, 62 Ohio St.2d 151, 157 , 404 N.E.2d 144 (1980). {¶ 12} The trial court did not conduct a separate oral evidentiary hearing on the common law motion to vacate default judgment for lack of personal jurisdiction, instead relying on the entire record, including, without limitation, the January 8, 2010 evidentiary hearing on damages. | 1 | 2019–2019 |
Blakemore v. Blakemore
green
2 sentences2019Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983), quoting State v. Adams, 62 Ohio St.2d 151, 157 , 404 N.E.2d 144 (1980). {¶ 12} The trial court did not conduct a separate oral evidentiary hearing on the common law motion to vacate default judgment for lack of personal jurisdiction, instead relying on the entire record, including, without limitation, the January 8, 2010 evidentiary hearing on damages. 2019Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 , 450 N.E.2d 1140 (1983), quoting State v. Adams, 62 Ohio St.2d 151, 157 , 404 N.E.2d 144 (1980). {¶ 12} The trial court did not conduct a separate oral evidentiary hearing on the common law motion to vacate default judgment for lack of personal jurisdiction, instead relying on the entire record, including, without limitation, the January 8, 2010 evidentiary hearing on damages. | 1 | 2019–2019 |
Giachetti v. Holmes
green
1 sentence2000SLABY, J., CONCUR. 1 McKinley avers that, because the trial court did not conduct an oral evidentiary hearing, it "need only make a prima facie showing of jurisdiction to withstand the motion to dismiss." Giachetti v. Holmes (1984), 14 Ohio App.3d 306 , 307 . | 1 | 2000–2000 |
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.