64 Ohio opinions name it 3 courts 1972–2026 10 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 |
|---|---|---|
Cater v. City of Clevelandgreen2 sentences2009R.C. 2744.02(B); Cater v. Cleveland (1998), 83 Ohio St.3d 24, 28, 697 N.E.2d 610 . {¶ 11} The second tier of the analysis considers whether any of the five exceptions listed in R.C. 2744.02(B) require the court to not apply the general rule of political subdivision immunity. 2006See Sobiski , supra; see, also, Cater v. Cleveland , 83 Ohio St.3d 24 , 28 , 1998-Ohio-421 , 697 N.E.2d 610 . {¶ 21} R.C. 2744.02 (A)(1) confers on all political subdivisions a blanket immunity, which provides that they are not liable for injury, death or loss to persons or property that occurred in relation to the performance of a governmental or propriety function. | 2 | 2 |
Buckmaster v. Buckmastergreen2 sentences2024Highland No. 13A13, 2014-Ohio-793, ¶ 13 . {¶62} Courts have held that it is error to not allow a competent child to testify in the parents’ divorce trial. 2019Highland No. 13A13, 2014-Ohio-793, ¶ 18 (“reliance upon an unwritten local rule” and/or “enforcement of a blanket rule disallowing child testimony in domestic matters * * * result[s] in a deprivation of due process”); but see Glimcher v. Glimcher, 29 Ohio App.2d 55 , 278 N.E.2d 37 (10th Dist.1971) (“[w]e do not condone the practice of a parent causing minor children to testify against the other parent in a divorce action”). | 1 | 3 |
Gerston v. Parma VTA, L.L.C.green1 sentence2025As a panel from this district recently concluded, prior litigation tangentially related to ongoing disputes does “not act as a blanket waiver for all other disputes between the parties.” Gerston v. Parma VTA, LLC, 2023-Ohio-1563, ¶ 18 (8th Dist.). | 1 | 1 |
State ex rel. Ware v. O'Malleygreen1 sentence2025“The plain language of R.C. 149.43(B)(8) ‘excuses a public office or official from having to provide a record when it relates to a criminal proceeding,’ but it ‘does not create a blanket rule that an 8 January Term, 2025 office or official may disregard an entire request when a portion thereof is subject to the prerelease approval of the sentencing judge.’” (Emphasis added in Ellis.) O’Malley at ¶ 13, quoting Ellis at ¶ 15. | 1 | 1 |
State ex rel. Ellis v. Cleveland Police Forensic Laboratory (Slip Opinion)green2 sentences2024The plain language of R.C. 149.43(B)(8) “excuses a public office or official from having to provide a record when it relates to a criminal proceeding,” but it “does not create a blanket rule that an office or official may disregard an entire request when a portion thereof is subject to the prerelease approval of the sentencing judge.” (Emphasis in original.) Ellis at ¶ 15; accord State ex rel. 2024The plain language of R.C. 149.43(B)(8) “excuses a public office or official from having to provide a record when it relates to a criminal proceeding,” but it “does not create a blanket rule that an office or official may disregard an entire request when a portion thereof is subject to the prerelease approval of the sentencing judge.” (Emphasis in original.) Ellis at ¶ 15; accord State ex rel. | 1 | 1 |
Buckman-Peirson v. Brannongreen1 sentence2024See Yeager v. Local Union 20, Teamsters, 6 Ohio St.3d 369, 374 (1983) (“we hold that in order to state a claim alleging the intentional infliction of emotional distress, the emotional distress alleged must be serious”); see also Buckman-Peirson v. Brannon, 2004-Ohio-6074, ¶ 41 (2d Dist.) (observing, “in Ohio at least, expert medical testimony concerning the plaintiff’s mental distress is not always required. | 1 | 1 |
Yeager v. Local Union 20, Teamsters, Chauffeurs, Warehousemen & Helpers of Americagreen1 sentence2024See Yeager v. Local Union 20, Teamsters, 6 Ohio St.3d 369, 374 (1983) (“we hold that in order to state a claim alleging the intentional infliction of emotional distress, the emotional distress alleged must be serious”); see also Buckman-Peirson v. Brannon, 2004-Ohio-6074, ¶ 41 (2d Dist.) (observing, “in Ohio at least, expert medical testimony concerning the plaintiff’s mental distress is not always required. | 1 | 1 |
State v. Hoffnergreen2 sentences2022See State v. Hoffner, 102 Ohio St.3d 358 , 2004-Ohio-3430 , 811 N.E.2d 48 . 2022See State v. Hoffner, 102 Ohio St.3d 358 , 2004-Ohio-3430 , 811 N.E.2d 48 . | 1 | 1 |
In Re Estate of Woodgreen1 sentence2014Wood, 55 Ohio App. 2d at 73-74 (noting that the facts and circumstances vary so much from case to case that it is impossible to set forth a blanket rule other than 6 We note that the United States Supreme Court has stated that there is a strong presumption as to the reasonableness of the lodestar and that an enhancement should be reserved for rare circumstances in which the lodestar does not adequately take into account a factor important to determining a reasonable fee. | 1 | 1 |
Strickland v. Washingtongreen2 sentences2013He also makes a blanket claim that counsel rendered deficient performance with respect to “arguments addressed elsewhere in [his] brief.” {¶ 81} To establish his claim, Wesson bears the burden to demonstrate that counsel’s performance “fell below an objective standard of reasonableness” as determined by “prevailing professional norms” and to demonstrate “a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Strickland v. Washington, 466 U.S. 668, 688, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). 2013He also makes a blanket claim that counsel rendered deficient performance with respect to “arguments addressed elsewhere in [his] brief.” {¶ 81} To establish his claim, Wesson bears the burden to demonstrate that counsel’s performance “fell below an objective standard of reasonableness” as determined by “prevailing professional norms” and to demonstrate “a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different.” Strickland v. Washington, 466 U.S. 668, 688, 694 , 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984). | 1 | 1 |
| River Terrace Condominium Assn. v. Lewisgreen | 1 | 1 |
| Cater v. Clevelandgreen | 1 | 1 |
| Sobiski v. Cuyahoga Cnty. D. C. F.S., Unpublished Decision (11-18-2004)green | 1 | 1 |
| Advance Mortgage Corp. v. Novakgreen | 1 | 1 |
| State v. Kirkgreen | 1 | 1 |
| Police & Fire Retirees of Ohio, Inc. v. Police & Firemen's Disability & Pension Fundgreen | 1 | 1 |
| National Labor Relations Board v. Robbins Tire & Rubber Co.green | 1 | 1 |
| Barker v. Stategreen | 1 | 1 |
| Griswold v. Connecticutgreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
Glimcher v. Glimchergreen2 sentences2019Highland No. 13A13, 2014-Ohio-793, ¶ 18 (“reliance upon an unwritten local rule” and/or “enforcement of a blanket rule disallowing child testimony in domestic matters * * * result[s] in a deprivation of due process”); but see Glimcher v. Glimcher, 29 Ohio App.2d 55 , 278 N.E.2d 37 (10th Dist.1971) (“[w]e do not condone the practice of a parent causing minor children to testify against the other parent in a divorce action”). 2019Highland No. 13A13, 2014-Ohio-793, ¶ 18 (“reliance upon an unwritten local rule” and/or “enforcement of a blanket rule disallowing child testimony in domestic matters * * * result[s] in a deprivation of due process”); but see Glimcher v. Glimcher, 29 Ohio App.2d 55 , 278 N.E.2d 37 (10th Dist.1971) (“[w]e do not condone the practice of a parent causing minor children to testify against the other parent in a divorce action”). | 1 | 1 |
| Case | Cited | Years |
|---|---|---|
Summers v. Slivinsky
green
2 sentences2007Id." Summers v. Slivinsky , 141 Ohio App.3d 82 , 86-87 , 2001-Ohio-3169 (overruled on other grounds), Allied Erecting Dismantling Co., Inc. v. Youngstown , 151 Ohio App.3d 16 , 2002-Ohio-5179 . {¶ 12} Under the first tier, Doolittle concedes that the Board of Health is a political subdivision pursuant to R.C. 2744.01 (F) and thus, is entitled to the blanket immunity as set forth in R.C. 2744.02 (A)(1). 2007Id." Summers v. Slivinsky, 141 Ohio App.3d 82 , 86-87 , 2001-Ohio-3169 (overruled on other grounds), Allied Erecting Dismantling Co., Inc. v. Youngstown, 151 Ohio App.3d 16 , 2002-Ohio-5179 . {¶ 12} Under the first tier, Doolittle concedes that the Board of Health is a political subdivision pursuant to R.C. 2744.01 (F) and thus, is entitled to the blanket immunity as set forth in R.C. 2744.02 (A)(1). | 2 | 2007–2007 |
Allied Erecting & Dismantling Co. v. City of Youngstown
green
2 sentences2007Id." Summers v. Slivinsky , 141 Ohio App.3d 82 , 86-87 , 2001-Ohio-3169 (overruled on other grounds), Allied Erecting Dismantling Co., Inc. v. Youngstown , 151 Ohio App.3d 16 , 2002-Ohio-5179 . {¶ 12} Under the first tier, Doolittle concedes that the Board of Health is a political subdivision pursuant to R.C. 2744.01 (F) and thus, is entitled to the blanket immunity as set forth in R.C. 2744.02 (A)(1). 2007Id." Summers v. Slivinsky, 141 Ohio App.3d 82 , 86-87 , 2001-Ohio-3169 (overruled on other grounds), Allied Erecting Dismantling Co., Inc. v. Youngstown, 151 Ohio App.3d 16 , 2002-Ohio-5179 . {¶ 12} Under the first tier, Doolittle concedes that the Board of Health is a political subdivision pursuant to R.C. 2744.01 (F) and thus, is entitled to the blanket immunity as set forth in R.C. 2744.02 (A)(1). | 2 | 2007–2007 |
Feitshans v. Darke County
green
2 sentences2005Furthermore, this Court has previously held that a governmental entity "need not have been acting in a discretionary manner in order to invoke the broad blanket immunity provided by R.C. 2744.02 (A)(1)." Feitshans v. Darke County (1996), 116 Ohio App.3d 14 , 22 , 686 N.E.2d 536 . 2005Furthermore, this Court has previously held that a governmental entity "need not have been acting in a discretionary manner in order to invoke the broad blanket immunity provided by R.C. 2744.02 (A)(1)." Feitshans v. Darke County (1996), 116 Ohio App.3d 14 , 22 , 686 N.E.2d 536 . | 2 | 1999–2005 |
Palazzolo v. Rhode Island
green
2 sentences2002A blanket rule that purchasers with notice have no compensation right when a claim becomes ripe is too blunt an instrument to accord with the duty to compensate for what is taken.” (Emphasis added and citations omitted.) Palazzolo, 533 U.S. at 626-628 , 121 S.Ct. at 2462-2463 , 150 L.Ed.2d at 613-614 . 2002A blanket rule that purchasers with notice have no compensation right when a claim becomes ripe is too blunt an instrument to accord with the duty to compensate for what is taken.” (Emphasis added and citations omitted.) Palazzolo, 533 U.S. at 626-628 , 121 S.Ct. at 2462-2463 , 150 L.Ed.2d at 613-614 . | 2 | 2002–2002 |
Harris v. Kennedy
neutral
2 sentences2000R.C. 2744.03 (A) (6) (a-c); Harris v. Kennedy (1996), 116 Ohio App.3d 687 , 691 . 1999R.C. § 2744.03 (A)(6) (a-c); Harris v. Kennedy (1996), 116 Ohio App.3d 687 , 691 . | 2 | 1999–2000 |
cluster 10839159
green
1 sentence2026Notably, perceivability was absent from the “physical defect” definition set out in Hoskins. 3 The School District argues, in its appellate brief, “[o]ne cannot determine or perceive the ‘hardness’ of [the sand in the pit] simply by feeling on one’s skin that the ambient air temperature is cold and observing that the surface of the sand may not have been raked.” (Emphasis added.) 2026-Ohio-1225, at ¶ 16 . | 1 | 2026–2026 |
Morgan v. Illinois
green
1 sentence2025Instead, in determining whether a juror was actually biased, a reviewing court must consider the entire record and determine whether it demonstrates that the juror was actually biased against the defendant. {¶ 55} In support of his argument, Rogers relies on three cases—Johnson v. Armontrout, 961 F.2d 748 (8th Cir. 1992), Hughes v. United States, 258 F.3d 453 (6th Cir. 2001), and Morgan v. Illinois, 504 U.S. 719 (1992)—in which courts in other contexts found collective responses by prospective jurors inadequate, by themselves, to ensure impartiality. | 1 | 2025–2025 |
Gerald Glenn Johnson v. Bill Armontrout
green
1 sentence2025Instead, in determining whether a juror was actually biased, a reviewing court must consider the entire record and determine whether it demonstrates that the juror was actually biased against the defendant. {¶ 55} In support of his argument, Rogers relies on three cases—Johnson v. Armontrout, 961 F.2d 748 (8th Cir. 1992), Hughes v. United States, 258 F.3d 453 (6th Cir. 2001), and Morgan v. Illinois, 504 U.S. 719 (1992)—in which courts in other contexts found collective responses by prospective jurors inadequate, by themselves, to ensure impartiality. | 1 | 2025–2025 |
Marshall Dwayne Hughes v. United States
green
1 sentence2025Instead, in determining whether a juror was actually biased, a reviewing court must consider the entire record and determine whether it demonstrates that the juror was actually biased against the defendant. {¶ 55} In support of his argument, Rogers relies on three cases—Johnson v. Armontrout, 961 F.2d 748 (8th Cir. 1992), Hughes v. United States, 258 F.3d 453 (6th Cir. 2001), and Morgan v. Illinois, 504 U.S. 719 (1992)—in which courts in other contexts found collective responses by prospective jurors inadequate, by themselves, to ensure impartiality. | 1 | 2025–2025 |
State v. Keenan
green
2 sentences2022State v. Keenan, 81 Ohio St.3d 133, 142 , 689 N.E.2d 929 (1998) (determining that the admission of hearsay was “[n]onconstitutional error”5 even though there was no Confrontation Clause violation because the declarant testified). 2022State v. Keenan, 81 Ohio St.3d 133, 142 , 689 N.E.2d 929 (1998) (determining that the admission of hearsay was “[n]onconstitutional error”5 even though there was no Confrontation Clause violation because the declarant testified). | 1 | 2022–2022 |
Cuyahoga County Department of Children & Family Services v. Evans
green
1 sentence2021In re B.E., 102 Ohio St.3d 388 , 2004-Ohio-3361 . {¶19} The supreme court rejected the blanket rule that an App.R. 9(C) statement may never be used where a court fails to comply with its recording obligation. | 1 | 2021–2021 |
Sauer v. Cox
neutral
1 sentence2019See, e.g., Civ.R. 64 (preserving remedies providing “for seizure of person or property” for the purposes of securing satisfaction of judgment during course of an action); Civ.R. 65 (providing for preliminary injunctions and temporary restraining orders); Sauer v. Cox, 5 Ohio N.P. 460 , 7 Ohio Dec. 507 , 508, 1897 Ohio Misc. | 1 | 2019–2019 |
Bellman v. American International Group
green
1 sentence2018Group, 113 Ohio St.3d 323 , 2007-Ohio- 2071, ¶7, quoting Black’s Law Dictionary 1149 (8th Ed.2004). {¶27} In adopting appellees’ position regarding the parol evidence rule, the trial court essentially established a blanket rule that all the elements must be satisfied within the document in every case. | 1 | 2018–2018 |
State ex rel. Gessner v. Vore
green
2 sentences2018Gessner v. Vore , 123 Ohio St.3d 96 , 2009-Ohio-4150 , 914 N.E.2d 376 , ¶ 5. " 'It is well established that pro se litigants are presumed to have knowledge of the law and legal procedures and that they are held to the same standard as litigants who are represented by counsel.' " (Italics sic.) State ex rel. 2018Gessner v. Vore , 123 Ohio St.3d 96 , 2009-Ohio-4150 , 914 N.E.2d 376 , ¶ 5. " 'It is well established that pro se litigants are presumed to have knowledge of the law and legal procedures and that they are held to the same standard as litigants who are represented by counsel.' " (Italics sic.) State ex rel. | 1 | 2018–2018 |
Mitchell v. United States
green
1 sentence2017Id. {¶ 25} White was a death penalty case in which the Kentucky Supreme Court originally found no error in the trial court’s denial, during the sentencing phase, of a blanket instruction that the defendant was “ ‘not compelled to testify and the fact that the defendant did not testify should not prejudice him in any way.” (Emphasis sic.) Id. at 1704. | 1 | 2017–2017 |
State v. Guerra
green
1 sentence2017Miami No. 2015-CA-28, 2016-Ohio-5647 , 2016 WL 4591377 , ¶ 9 ; see also R.C. 2953.08(D)(1). | 1 | 2017–2017 |
cluster 2358
green
2 sentences2014Perdue v. Kenny A., 559 U.S. 542 , 552-553, 130 S. Ct. 1662 , 176 L. 2014Perdue v. Kenny A., 559 U.S. 542 , 552-553, 130 S. Ct. 1662 , 176 L. | 1 | 2014–2014 |
Porter v. Ferrall, Unpublished Decision (12-5-2003)
green
1 sentence2014Portage No. 2002-P-0109, 2003-Ohio-6685, ¶ 18 . {¶28} We are mindful that a blanket rule requiring a hearing every time an objecting party invokes the talismanic words of Civ.R. 53(D)(4)(d) could lead to an abuse of that rule. | 1 | 2014–2014 |
| State v. Stephens green | 1 | 2012–2012 |
| State v. Johnson green | 1 | 2012–2012 |
Bedford v. McLeod
neutral
1 sentence2012No. 94649, 2011-Ohio-3380, ¶ 16 , citing Bedford v. Clark, 8th Dist. | 1 | 2012–2012 |
| State v. Martin, Unpublished Decision (11-15-2007) green | 1 | 2012–2012 |
| State Ex Rel. Fisher v. City of Cleveland, Unpublished Decision (8-19-2004) green | 1 | 2011–2011 |
| Harper v. Ohio Adult Parole Auth. neutral | 1 | 2011–2011 |
| State ex rel. Fisher v. City of Cleveland neutral | 1 | 2011–2011 |
| Ziegler v. Mahoning County Sheriff's Department green | 1 | 2009–2009 |
| Blue View Corp. v. Rhynes, Unpublished Decision (8-9-2006) green | 1 | 2009–2009 |
| Strother v. Hutchinson green | 1 | 2008–2008 |
| Rankin v. C.C.D.C.F.S., Unpublished Decision (12-21-2006) green | 1 | 2008–2008 |
| Richards v. Wisconsin green | 1 | 2007–2007 |
| State v. O'Brien green | 1 | 2007–2007 |
| State v. Said green | 1 | 2007–2007 |
| Curran v. State Automobile Mutual Ins. green | 1 | 2006–2006 |
| Huffman v. Hair Surgeon, Inc. green | 1 | 2006–2006 |
| O'Buck v. Cottonwood Village Condominium Ass'n green | 1 | 2006–2006 |
| Adomeit v. Baltimore green | 1 | 2004–2004 |
| Babbitt v. Norfolk & Western Railway Company green | 1 | 2003–2003 |
| Bondi v. Bondi green | 1 | 2003–2003 |
| Masino v. Masino green | 1 | 2003–2003 |
| Wehrum v. Wehrum green | 1 | 2003–2003 |
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.