elementary and fundamental requirement (Ohio) · Go Syfert
← Ohio issues

elementary and fundamental requirement in Ohio

72 Ohio opinions name it 4 courts 1980–2025 15 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
Mullane v. Central Hanover Bank & Trust Co.green
scotus · 1950 · cited in 58 Ohio opinions naming this issue, 1980–2025
2 sentences

2025Hanover Bank & Trust Co., 339 U.S. 306, 314 (1950) (“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.”).

2025Instead, it was only raised for the first time at the June 14, 2024 hearing, when Father's attorney brought it up as an afterthought, "while we're here." {¶ 16} "An elementary and fundamental requirement of due process in any proceeding . . . is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections." Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306, 314 (1950).

858
In Re Frinzlgreen
· 1949 · cited in 4 Ohio opinions naming this issue, 2019–2023
2 sentences

2023Hanover Bank & Trust Co., 339 U.S. 306, 314 , 70 S.Ct. 652 , 94 L.Ed. 865 (1950); accord In re Thompkins at ¶ 13. {¶38} Moreover, given the importance of the parent-child bond, “a Juvenile Court cannot make a valid order changing temporary commitment of a dependent child to a permanent one without a service of notice upon the parent of the child, strictly in accordance with the law.” In re Frinzl, 152 Ohio St. 164, 173 , 87 N.E.2d 583 (1949); accord In re S.S., 9th Dist.

2023Hanover Bank & Trust Co., 339 U.S. 306, 314 , 70 S.Ct. 652 , 94 L.Ed. 865 (1950); accord In re Thompkins at ¶ 13. {¶38} Moreover, given the importance of the parent-child bond, “a Juvenile Court cannot make a valid order changing temporary commitment of a dependent child to a permanent one without a service of notice upon the parent of the child, strictly in accordance with the law.” In re Frinzl, 152 Ohio St. 164, 173 , 87 N.E.2d 583 (1949); accord In re S.S., 9th Dist.

44
Ohio Valley Radiology Associates, Inc. v. Ohio Valley Hospital Ass'ngreen
ohio · 1986 · cited in 9 Ohio opinions naming this issue, 2000–2021
2 sentences

2021Assn., 28 Ohio St.3d 118, 125 , 502 N.E.2d 599 (1986). “ ‘An elementary and fundamental requirement of due process in any proceeding * * * is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ ” Id. at 124-125 , quoting Mullane v. Cent.

2021Assn., 28 Ohio St.3d 118, 125 , 502 N.E.2d 599 (1986). “ ‘An elementary and fundamental requirement of due process in any proceeding * * * is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ ” Id. at 124-125 , quoting Mullane v. Cent.

19
Akron-Canton Regional Airport Authority v. Swinehartgreen
ohio · 1980 · cited in 7 Ohio opinions naming this issue, 1981–2023
2 sentences

2023“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” Id. at 406 , quoting Mullane v. Cent.

2008See, also, Akron-Canton Regional Airport Authority v. Swinehart (1980), 62 Ohio St.2d 403 , 406 (an elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections).

17
Korn v. Ohio State Medical Boardgreen
ohioctapp · 1988 · cited in 2 Ohio opinions naming this issue, 2010–2015
2 sentences

2015Bd., 61 Ohio App.3d 677, 684 (10th Dist.1988), citing Luff v. State, 117 Ohio St.2d 102 (1927). " 'An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.' " Althof v. Ohio State Bd. of Psychology, 10th Dist.

2010Bd. (1988), 61 Ohio App.3d 677, 684 , 573 N.E.2d 1100 , citing Luff v. State (1927), 117 Ohio St. 102 , 157 N.E. 388 . “ ‘An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ ” Althof v. Ohio State Bd. of Psychology, 10th Dist.

12
Samson Sales, Inc. v. Honeywell, Inc.green
ohio · 1981 · cited in 1 Ohio opinions naming this issue, 2021–2021
2 sentences

2021“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” Samson Sales, Inc. v. Honeywell, Inc., 66 Ohio St.2d 290, 293 , 421 N.E.2d 522, 524 (1981). {¶34} TM Three offered as proof of notice the affidavit of Nicolas Sandberg who claims he served Rodriguez with a copy of the complaint at a Delray Beach, Florida, address.

2021“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” Samson Sales, Inc. v. Honeywell, Inc., 66 Ohio St.2d 290, 293 , 421 N.E.2d 522, 524 (1981). {¶34} TM Three offered as proof of notice the affidavit of Nicolas Sandberg who claims he served Rodriguez with a copy of the complaint at a Delray Beach, Florida, address.

11
Richard T. Kiko Agency, Inc. v. Ohio Department of Commercegreen
ohio · 1990 · cited in 1 Ohio opinions naming this issue, 2017–2017
1 sentence

2017Kiko Agency, Inc. v. Ohio Dept. of Commerce, Div. of Real Estate, 48 Ohio St.3d 74, 76 (1990)(The state has a valid interest in promoting the character, honesty, and intellectual competence of real estate brokers, and the right to engage in the real estate business is in the nature of a privilege granted by the state). {¶ 20} " 'An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to prese

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 (20)

CaseCitedYears
In re Thompkins green
ohio · 2007
2 sentences

2023In re Thompkins, 115 Ohio St.3d 409 , 2007-Ohio-5238 , 875 N.E.2d 582 , ¶ 13. “ ‘An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ ” Id., quoting Mullane v. Cent.

2018In re Thompkins, 115 Ohio St.3d 409 , 2007-Ohio-5238 , 875 N.E.2d 582 , ¶13. ‘An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ Id., quoting Mullane v. Hanover Bank & Trust Co., 339 U.S. 306 , 70 S.Ct. 652 , 94 L.Ed. 865 (1950).” O’Malley v. O’Malley, 8th Dist.

42014–2023
Althof v. Ohio State Bd. of Psycho., Unpublished Decision (3-8-2007) green
ohioctapp · 2007
2 sentences

2017No. 05AP-1169, 2007-Ohio-1010, ¶ 19 , quoting Mullane v. Cent.

2016No. 05AP-1169, 2007-Ohio-1010, ¶ 19 , quoting Mullane v. Cent.

42010–2017
In Re Smith green
ohioctapp · 1991
2 sentences

2005In re Jones (Nov. 22, 2000), Cuyahoga App. No. 76533, quoting, In re Smith (1991), 77 Ohio App.3d 1 , 16 , 601 N.E.2d 45 . {¶ 13} Juv.R.

2005In re Jones (Nov. 22, 2000), Cuyahoga App. No. 76533, quoting, In re Smith (1991), 77 Ohio App.3d 1 , 16 , 601 N.E.2d 45 . {¶ 13} Juv.R.

22004–2005
Mitchell v. Mitchell green
ohio · 1980
2 sentences

2003Janice's affidavit does not refute Thomas' sworn statement that he did not receive a copy of the complaint. {¶ 10} Furthermore, "an elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections." Mullane v. Central Hanover Bank Trust Co. (1950), 339 U.S. 306 , 314 ; Mitchell v. Mitchell (1980), 64 Ohio St.2d 49 , 51 .

1981The standard of due process, first enunciated in Mullane v. Central Hanover Bank & Trust Co. (1950), 339 U. S. 306 , at page 314, is as follows: “An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections. ” (Emphasis added.) See, also, Mitchell v. Mitchell, supra, at page 51; Regional Airport Authority v. Swinehart, supra, at page 406; In re Foreclosure of Liens (198

21981–2003
In re Foreclosure of Liens for Delinquent Taxes green
ohio · 1980
2 sentences

1981The standard of due process, first enunciated in Mullane v. Central Hanover Bank & Trust Co. (1950), 339 U. S. 306 , at page 314, is as follows: “An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections. ” (Emphasis added.) See, also, Mitchell v. Mitchell, supra, at page 51; Regional Airport Authority v. Swinehart, supra, at page 406; In re Foreclosure of Liens (198

1980In reply, we turn to the standard enunciated in Mullane v. Central Hanover Bank & Trust Co. (1950), 339 U.S. 306 , at page 314, as follows: “An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” (Emphasis added.) See In re Foreclosure of Liens, supra. So long as service is “reasonably calculated” to reach interested parties, then the service is constitutionally

21980–1981
Armstrong v. Manzo green
scotus · 1965
2 sentences

2021Assn., 28 Ohio St.3d 118, 125 , 502 N.E.2d 599 (1986). ‘“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’” Armstrong v. Manzo, 380 U.S. 545, 550 , 85 S.Ct. 1187 , 14 L.Ed.2d 62 (1965), quoting Mullane v. Cent.

2021Assn., 28 Ohio St.3d 118, 125 , 502 N.E.2d 599 (1986). ‘“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’” Armstrong v. Manzo, 380 U.S. 545, 550 , 85 S.Ct. 1187 , 14 L.Ed.2d 62 (1965), quoting Mullane v. Cent.

12021–2021
Howard v. Ohio State Racing Comm. neutral
ohioctapp · 2019
1 sentence

2021“An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and Scioto App. No. 20CA3925 20 afford them an opportunity to present their objections.” Howard v. Ohio State Racing Comm., 2019-Ohio-4013 , 145 N.E.3d 1254 at ¶ 26 (10th Dist. 2019); Mullane v. Cent.

12021–2021
Hagar v. Reclamation District No. 108 green
scotus · 1884
1 sentence

2020No. 108, 111 U.S. -41- Case Nos. 10-19-10, 11, 12, 13 701, 708, 4 S.Ct. 663 (1884), and citing Caldwell v. Carthage, 49 Ohio St. 334 , 348 (1892). “‘An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’” Id., quoting Mullane v. Cent.

12020–2020
County Security Agency v. The Ohio Department of Commerce v. Michael J. Betzold, Intervenor-Appellant green
ca6 · 2002
1 sentence

2018Agency v. Ohio Dept. of Commerce , 296 F.3d 477 , 484 (6th Cir.2002). {¶ 20} "An elementary and fundamental requirement of due process in any proceeding * * * is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections. * * *" Ohio Valley at 124, 502 N.E.2d 599 , citing Mullane v. Cent.

12018–2018
Fuentes v. Shevin green
scotus · 1972
2 sentences

2018Hanover Bank & Trust Co. , 339 U.S. 306 , 314, 70 S.Ct. 652 , 657, 94 L.Ed. 865 (1950). "[T]he right to notice and an opportunity to be heard 'must be granted at a meaningful time and in a meaningful manner.' " (Citation omitted.) Fuentes v. Shevin , 407 U.S. 67 , 80, 92 S.Ct. 1983 , 32 L.Ed.2d 556 (1972).

2018Hanover Bank & Trust Co. , 339 U.S. 306 , 314, 70 S.Ct. 652 , 657, 94 L.Ed. 865 (1950). "[T]he right to notice and an opportunity to be heard 'must be granted at a meaningful time and in a meaningful manner.' " (Citation omitted.) Fuentes v. Shevin , 407 U.S. 67 , 80, 92 S.Ct. 1983 , 32 L.Ed.2d 556 (1972).

12018–2018
Luff v. State green
ohio · 1927
2 sentences

2010Bd. (1988), 61 Ohio App.3d 677, 684 , 573 N.E.2d 1100 , citing Luff v. State (1927), 117 Ohio St. 102 , 157 N.E. 388 . “ ‘An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ ” Althof v. Ohio State Bd. of Psychology, 10th Dist.

2010Bd. (1988), 61 Ohio App.3d 677, 684 , 573 N.E.2d 1100 , citing Luff v. State (1927), 117 Ohio St. 102 , 157 N.E. 388 . “ ‘An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.’ ” Althof v. Ohio State Bd. of Psychology, 10th Dist.

12010–2010
Atkinson v. Grumman Ohio Corp. green
ohio · 1988
1 sentence

2008Atkinson v. Grumman Ohio Corp. (1988), 37 Ohio St.3d 80 , 85 ; Crist v. Battle Run Fire Dist. (1996), 115 Ohio App.3d 191 , 197 . {¶ 21} "An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated under all circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections. * * * The notice must be of such nature as reasonably to convey the required information, * * * and it must afford a reasonable time for those interested to make their appearanc

12008–2008
Crist v. Battle Run Fire Dist. green
ohioctapp · 1996
1 sentence

2008Atkinson v. Grumman Ohio Corp. (1988), 37 Ohio St.3d 80 , 85 ; Crist v. Battle Run Fire Dist. (1996), 115 Ohio App.3d 191 , 197 . {¶ 21} "An elementary and fundamental requirement of due process in any proceeding which is to be accorded finality is notice reasonably calculated under all circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections. * * * The notice must be of such nature as reasonably to convey the required information, * * * and it must afford a reasonable time for those interested to make their appearanc

12008–2008
Dusenbery v. United States green
scotus · 2002
2 sentences

2007Dusenbery v. United States (2002), 534 U.S. 161, 170 , 122 S.Ct. 694 , 151 L.Ed.2d 597 .

2007Dusenbery v. United States (2002), 534 U.S. 161, 170 , 122 S.Ct. 694 , 151 L.Ed.2d 597 .

12007–2007
Sansea, Inc. v. Mahoning County Board of Elections neutral
ohioctapp · 1996
1 sentence

1999Bd. of Elections (1996), 113 Ohio App.3d 351 , 357 , quoting Mullane v. Central Hanover Bank Trust Co. (1950), 339 U.S. 306 , 314 , 94 L.Ed. 865 , 873 .

11999–1999
Schroeder v. City of New York green
scotus · 1962
2 sentences

1997Further, “An elementary and fundamental requirement of due process in- any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” (Citations omitted.) Schroeder v. City of New York (1962) 371 U.S. 208, 211 , 83 S.Ct. 279, 282 , 9 L.Ed.2d 255, 258-259 .

1997Further, “An elementary and fundamental requirement of due process in- any proceeding which is to be accorded finality is notice reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action and afford them an opportunity to present their objections.” (Citations omitted.) Schroeder v. City of New York (1962) 371 U.S. 208, 211 , 83 S.Ct. 279, 282 , 9 L.Ed.2d 255, 258-259 .

11997–1997
Roller v. Holly green
scotus · 1900
1 sentence

1987Milliken v. Meyer, 311 U.S. 457 ; Grannis v. Ordean, 234 U.S. 385 ; Priest v. Las Vegas, 232 U.S. 604 ; Roller v. Holly, 176 U.S. 398 .

11987–1987
Priest v. Trustees of Town of Las Vegas green
scotus · 1914
1 sentence

1987Milliken v. Meyer, 311 U.S. 457 ; Grannis v. Ordean, 234 U.S. 385 ; Priest v. Las Vegas, 232 U.S. 604 ; Roller v. Holly, 176 U.S. 398 .

11987–1987
Grannis v. Ordean green
scotus · 1914
1 sentence

1987Milliken v. Meyer, 311 U.S. 457 ; Grannis v. Ordean, 234 U.S. 385 ; Priest v. Las Vegas, 232 U.S. 604 ; Roller v. Holly, 176 U.S. 398 .

11987–1987
Milliken v. Meyer green
scotus · 1941
1 sentence

1987Milliken v. Meyer, 311 U.S. 457 ; Grannis v. Ordean, 234 U.S. 385 ; Priest v. Las Vegas, 232 U.S. 604 ; Roller v. Holly, 176 U.S. 398 .

11987–1987

Statutes the citing opinions construe

OH § Ohio Rev. Code § 119.12 (9) OH § Ohio Rev. Code § 2151.414 (8) OH § Ohio Rev. Code § 119.07 (5) OH § Ohio Rev. Code § 2151.28 (5) OH § Ohio Rev. Code § 2151.413 (5) OH § Ohio Rev. Code § 2151.29 (4) OH § Ohio Rev. Code § 2151.353 (4) OH § Ohio Rev. Code § 2151.419 (4) OH § Ohio Rev. Code § 121.22 (3) OH § Ohio Rev. Code § 2151.01 (3) OH § Ohio Rev. Code § 2151.352 (3) OH § Ohio Rev. Code § 3109.04 (3)

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.

Where else courts name it

OH 72 (1980–2025) TX 50 (1965–2023) CA 42 (1953–2026) IN 36 (1894–2023) NY 32 (1966–2026) LA 24 (1968–2024) IL 23 (1899–2025) MI 22 (1951–2026) PA 19 (1973–2023) MO 19 (1972–2024) MD 16 (1969–2024) OK 15 (1975–2011) CT 15 (1984–2023) NC 13 (1951–2024) NH 12 (1978–2023) NJ 12 (1971–2020) FL 12 (1981–2024) VA 11 (1978–2016) AZ 10 (1967–2021) GA 10 (1974–2003) AL 10 (1904–2025) MA 10 (1988–2026) WA 9 (1978–2018) KS 8 (1978–2005) CO 8 (1994–2011) OR 8 (1953–2020) SD 7 (1991–2015) NM 7 (1995–2020) WI 6 (1981–2020) VT 6 (1997–2020) HI 6 (1923–2022) UT 6 (1983–2020) DC 6 (1975–2003) MS 5 (1984–2016) TN 5 (1976–2015) MN 5 (1956–2018) AR 4 (2002–2018) RI 4 (1963–2011) IA 4 (1974–2016) WV 4 (1990–2019) MT 3 (1926–2007) ND 3 (1986–2014) KY 3 (1988–2021) NV 3 (1977–1998) AK 3 (1984–1994) ME 3 (1998–2007) ID 2 (1958–1986) NE 2 (1984–1988) SC 2 (2001–2005) DE 2 (2018–2019)

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.

← Caselaw search · G Cite Topics · Brief Check