plain meaning rule (Ohio) · Go Syfert
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plain meaning rule in Ohio

11 Ohio opinions name it 3 courts 1984–2021 1 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 (4)

CaseFollowedCited
Griffin v. Oceanic Contractors, Inc.green
scotus · 1982 · cited in 2 Ohio opinions naming this issue, 2019–2019
2 sentences

2019The absurd-result exception to the plain-meaning rule provides “that ‘interpretations of a statute which would 7 produce absurd results are to be avoided if alternative interpretations consistent with the legislative purpose are available.’” Lawson v. FMR, L.L.C., 571 U.S. 429, 471 (2014) (Sotomayor, J., dissenting), quoting Griffin v. Oceanic Contrs., Inc., 458 U.S. 564, 575 (1982).

2019The absurd-result exception to the plain-meaning rule provides “that ‘interpretations of a statute which would produce absurd results are to be avoided if alternative interpretations consistent with the legislative purpose are available.’” Lawson v. FMR, L.L.C., 571 U.S. 429, 471 (2014) (Sotomayor, J., dissenting), quoting Griffin v. Oceanic Contrs., Inc., 458 U.S. 564, 575 (1982). {¶13} Under the circumstances, strictly applying R.C. 2953.61 would require a court to deny an application to seal without considering the substantive merits of the pleading merely because an offender has a minor mi

22
Lawson v. FMR LLCgreen
scotus · 2014 · cited in 2 Ohio opinions naming this issue, 2019–2019
2 sentences

2019The absurd-result exception to the plain-meaning rule provides “that ‘interpretations of a statute which would 7 produce absurd results are to be avoided if alternative interpretations consistent with the legislative purpose are available.’” Lawson v. FMR, L.L.C., 571 U.S. 429, 471 (2014) (Sotomayor, J., dissenting), quoting Griffin v. Oceanic Contrs., Inc., 458 U.S. 564, 575 (1982).

2019The absurd-result exception to the plain-meaning rule provides “that ‘interpretations of a statute which would produce absurd results are to be avoided if alternative interpretations consistent with the legislative purpose are available.’” Lawson v. FMR, L.L.C., 571 U.S. 429, 471 (2014) (Sotomayor, J., dissenting), quoting Griffin v. Oceanic Contrs., Inc., 458 U.S. 564, 575 (1982). {¶13} Under the circumstances, strictly applying R.C. 2953.61 would require a court to deny an application to seal without considering the substantive merits of the pleading merely because an offender has a minor mi

22
State v. Wellsgreen
ohio · 2001 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019See State v. White, 142 Ohio St. 3d 277 , 2015-Ohio-492, 29 N.E.3d 939 , ¶ 29, quoting State v. Wells, 91 Ohio St. 3d 32 , 34, 740 N.E.2d 1097 (2001) (“ ‘statutes will be construed to avoid unreasonable or absurd consequences’ ”).

2019See State v. White, 142 Ohio St. 3d 277 , 2015-Ohio-492, 29 N.E.3d 939 , ¶ 29, quoting State v. Wells, 91 Ohio St. 3d 32 , 34, 740 N.E.2d 1097 (2001) (“ ‘statutes will be construed to avoid unreasonable or absurd consequences’ ”).

11
State v. Whitegreen
ohio · 2015 · cited in 1 Ohio opinions naming this issue, 2019–2019
2 sentences

2019See State v. White, 142 Ohio St. 3d 277 , 2015-Ohio-492, 29 N.E.3d 939 , ¶ 29, quoting State v. Wells, 91 Ohio St. 3d 32 , 34, 740 N.E.2d 1097 (2001) (“ ‘statutes will be construed to avoid unreasonable or absurd consequences’ ”).

2019See State v. White, 142 Ohio St. 3d 277 , 2015-Ohio-492, 29 N.E.3d 939 , ¶ 29, quoting State v. Wells, 91 Ohio St. 3d 32 , 34, 740 N.E.2d 1097 (2001) (“ ‘statutes will be construed to avoid unreasonable or absurd consequences’ ”).

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 (11)

CaseCitedYears
Food Marketing Institute v. Argus Leader Media green
scotus · 2019
2 sentences

2021In other words, when the statutory language is unambiguous, courts should not rely on extrinsic information to discern the meaning of the statute, but should instead conduct a “careful examination of the 46 January Term, 2021 ordinary meaning and structure of the law itself.” Food Marketing Inst. v. Argus Leader Media, ___ U.S. ___, 139 S.Ct. 2356, 2364 , 204 L.Ed.2d 742 (2019). {¶ 120} This does not mean that a court is forbidden from using intrinsic linguistic tools to understand a statute’s plain meaning.

2021In other words, when the statutory language is unambiguous, courts should not rely on extrinsic information to discern the meaning of the statute, but should instead conduct a “careful examination of the 46 January Term, 2021 ordinary meaning and structure of the law itself.” Food Marketing Inst. v. Argus Leader Media, ___ U.S. ___, 139 S.Ct. 2356, 2364 , 204 L.Ed.2d 742 (2019). {¶ 120} This does not mean that a court is forbidden from using intrinsic linguistic tools to understand a statute’s plain meaning.

12021–2021
State ex rel. Clay v. Cuyahoga Cty. Med. Examiner's Office (Slip Opinion) green
ohio · 2017
2 sentences

2019Clay v. Cuyahoga Co. Medical Examiner’s Office, 152 Ohio St.3d 163 , 2017-Ohio-8714, ¶26 , quoting Manning, The Absurdity Doctrine, 116 Harv.L.Rev. 2387, 2476 (2003).

2019Clay v. Cuyahoga Co. Medical Examiner’s Office, 152 Ohio St.3d 163 , 2017-Ohio-8714, ¶26 , quoting Manning, The Absurdity Doctrine, 116 Harv.L.Rev. 2387, 2476 (2003).

12019–2019
United States v. American Trucking Associations green
scotus · 1940
1 sentence

2019Trucking Assns., 310 U.S. 534 , 543– 544 (1940). {¶27} “The absurd-result exception to the plain-meaning rule of construction ‘entails the imputation of legislative intent based on the judge’s perception’ and ‘vastly expands the [c]ourt’s authority.’” State ex rel.

12019–2019
Aultman Hospital Ass'n v. Community Mutual Insurance green
ohio · 1989
2 sentences

2019The Eighth District relied on our statement in Anders, 99 Ohio St.3d 156 , 2003-Ohio-3048 , 789 N.E.2d 1094, at ¶ 34 , that common words in a contract should “be given their ordinary meaning unless manifest absurdity results * * *.” Although we have repeated this statement on numerous occasions, e.g., Aultman, 46 Ohio St.3d at 54 , 544 N.E.2d 920 ; Alexander, at paragraph two of the syllabus, this exception to the plain- meaning rule is narrow in scope and is necessarily limited by the meaning of the term “manifest absurdity” itself.

2019The Eighth District relied on our statement in Anders, 99 Ohio St.3d 156 , 2003-Ohio-3048 , 789 N.E.2d 1094, at ¶ 34 , that common words in a contract should “be given their ordinary meaning unless manifest absurdity results * * *.” Although we have repeated this statement on numerous occasions, e.g., Aultman, 46 Ohio St.3d at 54 , 544 N.E.2d 920 ; Alexander, at paragraph two of the syllabus, this exception to the plain- meaning rule is narrow in scope and is necessarily limited by the meaning of the term “manifest absurdity” itself.

12019–2019
Cincinnati Insurance v. Anders green
ohio · 2003
2 sentences

2019The Eighth District relied on our statement in Anders, 99 Ohio St.3d 156 , 2003-Ohio-3048 , 789 N.E.2d 1094, at ¶ 34 , that common words in a contract should “be given their ordinary meaning unless manifest absurdity results * * *.” Although we have repeated this statement on numerous occasions, e.g., Aultman, 46 Ohio St.3d at 54 , 544 N.E.2d 920 ; Alexander, at paragraph two of the syllabus, this exception to the plain- meaning rule is narrow in scope and is necessarily limited by the meaning of the term “manifest absurdity” itself.

2019The Eighth District relied on our statement in Anders, 99 Ohio St.3d 156 , 2003-Ohio-3048 , 789 N.E.2d 1094, at ¶ 34 , that common words in a contract should “be given their ordinary meaning unless manifest absurdity results * * *.” Although we have repeated this statement on numerous occasions, e.g., Aultman, 46 Ohio St.3d at 54 , 544 N.E.2d 920 ; Alexander, at paragraph two of the syllabus, this exception to the plain- meaning rule is narrow in scope and is necessarily limited by the meaning of the term “manifest absurdity” itself.

12019–2019
Blair v. Sugarcreek Twp. Bd. of Trustees green
ohio · 2012
1 sentence

2015Blair v. Bd. of Trustees of Sugarcreek Twp., 132 Ohio St.3d 151 , 2012- Ohio-2165, 970 N.E.2d 884 , ¶ 19. {¶29} Applying a plain-meaning analysis, ingress is defined as “[a] means or place of entering,” and egress is defined as “[a] path or opening for going out; an exit.” American Heritage Dictionary 901, 571 (4th Ed.2000).

12015–2015
Gravillis v. Coldwell Banker Residential Brokerage Co. green
calctapp · 2006
2 sentences

2012Gravillis v. Coldwell Banker Residential Brokerage Co., 143 Cal.App.4th 761, 774-775 , 49 Cal.Rptr.3d 531 (2d Dist. 2006).

2012Gravillis v. Coldwell Banker Residential Brokerage Co., 143 Cal.App.4th 761, 774-775 , 49 Cal.Rptr.3d 531 (2d Dist. 2006).

12012–2012
Watt v. Alaska green
scotus · 1981
2 sentences

2007For instance, the Supreme Court of the United States has recognized that “ascertainment of the meaning apparent on the face of a single statute need not end the inquiry * * * because the plain-meaning rule is ‘rather an axiom of experience than a rule of law, and does not preclude consideration of persuasive evidence if it exists.’ * * * [Thus] [t]he circumstances of the enactment of particular legislation may persuade a court that Congress did not intend words of common meaning to have their literal effect.” Watt v. Alaska (1981), 451 U.S. 259, 265-266 , 101 S.Ct. 1673 , 68 L.Ed.2d 80 .

2007For instance, the Supreme Court of the United States has recognized that “ascertainment of the meaning apparent on the face of a single statute need not end the inquiry * * * because the plain-meaning rule is ‘rather an axiom of experience than a rule of law, and does not preclude consideration of persuasive evidence if it exists.’ * * * [Thus] [t]he circumstances of the enactment of particular legislation may persuade a court that Congress did not intend words of common meaning to have their literal effect.” Watt v. Alaska (1981), 451 U.S. 259, 265-266 , 101 S.Ct. 1673 , 68 L.Ed.2d 80 .

12007–2007
State ex rel. Brennan v. Vinton County Local School District Board of Education green
ohio · 1985
2 sentences

1992Local Bd. of Edn. (1985), 18 Ohio St.3d 208, 209 , 18 OBR 271, 272, 480 N.E.2d 476, 477 , this court stated that under the plain-meaning rule stipulated in R.C. 1.42, the foregoing statutory provision 1 must be viewed as mandating written notice whenever the board of education chooses not to reemploy administrators.

1992Local Bd. of Edn. (1985), 18 Ohio St.3d 208, 209 , 18 OBR 271, 272, 480 N.E.2d 476, 477 , this court stated that under the plain-meaning rule stipulated in R.C. 1.42, the foregoing statutory provision 1 must be viewed as mandating written notice whenever the board of education chooses not to reemploy administrators.

11992–1992
State ex rel. Lee v. Bellefontaine City Board of Education neutral
ohio · 1985
1 sentence

1985Lee, supra, and the plain-meaning rule stipulated in R.C. 1.42, to hold the written notice provision in R.C. 3319.02 to be mandatory.

11985–1985
Canton v. Imperial Bowling Lanes, Inc. green
ohio · 1968
2 sentences

1984Words and phrases that have acquired a technical or particular meaning, whether by legislative definition or otherwise, shall be construed accordingly." (Emphasis added.) The majority correctly states, “ ‘[t]he General Assembly will not be presumed to have intended to enact a law producing unreasonable or absurd consequences. * * *’ Canton v. Imperial Bowling Lanes (1968), 16 Ohio St. 2d 47 [ 45 O.O.2d 327 ], paragraph four of the syllabus.” Yet, it is difficult to conceive of any reason for the legislature to have intended for Muny Light to erect poles next to existing CEI poles to serve iden

1984Words and phrases that have acquired a technical or particular meaning, whether by legislative definition or otherwise, shall be construed accordingly." (Emphasis added.) The majority correctly states, “ ‘[t]he General Assembly will not be presumed to have intended to enact a law producing unreasonable or absurd consequences. * * *’ Canton v. Imperial Bowling Lanes (1968), 16 Ohio St. 2d 47 [ 45 O.O.2d 327 ], paragraph four of the syllabus.” Yet, it is difficult to conceive of any reason for the legislature to have intended for Muny Light to erect poles next to existing CEI poles to serve iden

11984–1984

Where else courts name it

NM 286 (1952–2026) MD 133 (1907–2023) CA 121 (1932–2026) WA 112 (1990–2025) TX 103 (1973–2026) CT 92 (1986–2025) WI 81 (1968–2025) SC 71 (1997–2026) FL 38 (1981–2025) AK 36 (1980–2024) MI 34 (1981–2024) IL 31 (1984–2025) VT 31 (1980–2026) VA 25 (1989–2025) NV 24 (1986–2019) AZ 23 (1976–2025) UT 22 (1990–2024) AL 18 (2001–2018) NY 17 (1977–2015) MN 17 (1986–2016) PA 16 (1982–2026) DC 16 (1977–2024) HI 15 (1983–2023) NC 13 (2005–2026) KY 12 (2005–2025) CO 12 (1995–2026) OH 11 (1984–2021) MS 10 (2001–2018) IA 10 (1986–2020) NH 9 (1978–2013) DE 8 (1994–2017) MO 8 (1979–2022) ME 7 (1991–2013) NJ 6 (1961–2021) MA 6 (1986–2013) WY 6 (1991–2007) RI 6 (2005–2017) TN 5 (1992–2019) AR 5 (1996–2006) KS 4 (1994–2014) ID 4 (1990–2022) IN 4 (1992–2023) OK 4 (1973–2013) MT 4 (1985–1995) VI 3 (2008–2025) NE 3 (1986–2025) SD 2 (2000–2025) WV 2 (2014–2014)

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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