Ohio rule in Texas

7 Texas opinions name it 3 courts 1945–2018 0 in the last five years

The cases below were cited by Texas 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 (13)

Case	Followed	Cited
Pledger v. Easco Hand Tools, Inc.green ark · 1990 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996See generally Duval Sierrita Corp. v. Arizona Dep’t of Revenue, 116 Ariz. 200 , 568 P.2d 1098, 1104 (Ct.App.1977) ("used directly”) (stating that "we believe the corollary to the ‘Ohio rule’ and 163 its interpretation by that state is too narrow”); Pledger v. Easco Hand Tools, Inc., 304 Ark. 47 , 800 S.W.2d 690 (1990) ("used directly"); Arkansas Ry. 1996See generally Duval Sierrita Corp. v. Arizona Dep’t of Revenue, 116 Ariz. 200 , 568 P.2d 1098, 1104 (Ct.App.1977) ("used directly”) (stating that "we believe the corollary to the ‘Ohio rule’ and 163 its interpretation by that state is too narrow”); Pledger v. Easco Hand Tools, Inc., 304 Ark. 47 , 800 S.W.2d 690 (1990) ("used directly"); Arkansas Ry.	2	2
Courier Citizen Co. v. Commissioner of Corporations & Taxationgreen mass · 1971 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire	2	2
Duval Sierrita Corp. v. Arizona Department of Revenuegreen arizctapp · 1977 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996See generally Duval Sierrita Corp. v. Arizona Dep’t of Revenue, 116 Ariz. 200 , 568 P.2d 1098, 1104 (Ct.App.1977) ("used directly”) (stating that "we believe the corollary to the ‘Ohio rule’ and 163 its interpretation by that state is too narrow”); Pledger v. Easco Hand Tools, Inc., 304 Ark. 47 , 800 S.W.2d 690 (1990) ("used directly"); Arkansas Ry. 1996See generally Duval Sierrita Corp. v. Arizona Dep’t of Revenue, 116 Ariz. 200 , 568 P.2d 1098, 1104 (Ct.App.1977) ("used directly”) (stating that "we believe the corollary to the ‘Ohio rule’ and 163 its interpretation by that state is too narrow”); Pledger v. Easco Hand Tools, Inc., 304 Ark. 47 , 800 S.W.2d 690 (1990) ("used directly"); Arkansas Ry.	2	2
Floyd Charcoal Co. v. Director of Revenuegreen mo · 1980 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett , 467 S.W.2d 598 (Ky. Ct. App. 1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation , 266 N.E.2d 284, 290 (Mass. 1971) ("used directly") (stating that "[w]e think the Ohio cases are too restrictive"); Floyd Charcoal Co. v. Director of Revenue , 599 S.W.2d 173, 177 (Mo. 1980) ("used directly") (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem"); Niagara Mohawk Power Corp. v. Wanamaker , 144 N.Y.S.2d 458, 461-62 (App. Div. 1955) ("use[d] . . . directly and exclusively") (stating that "`directly a	2	2
Niagara Mohawk Power Corp. v. Wanamakergreen nyappdiv · 1955 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire	2	2
Manitowoc Co. v. City of Sturgeon Baygreen wisctapp · 1984 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire	1	2
State Board of Equalization v. Cheyenne Newspapers, Inc.green wyo · 1980 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett , 467 S.W.2d 598 (Ky. Ct. App. 1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation , 266 N.E.2d 284, 290 (Mass. 1971) ("used directly") (stating that "[w]e think the Ohio cases are too restrictive"); Floyd Charcoal Co. v. Director of Revenue , 599 S.W.2d 173, 177 (Mo. 1980) ("used directly") (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem"); Niagara Mohawk Power Corp. v. Wanamaker , 144 N.Y.S.2d 458, 461-62 (App. Div. 1955) ("use[d] . . . directly and exclusively") (stating that "`directly a	1	2
cluster 18488green · · cited in 1 Texas opinions naming this issue, 2018–2018 1 sentence 2018See Guidry, 188 F.3d at 628 ; Searcy, 496 S.W.3d at 67 ; see also Trois v. Apple Tree Auction Ctr., 882 F.3d 485 , 487–88, 490–91 (5th Cir. 2018) (recognizing the existence of specific jurisdiction over an Ohio defendant for a fraud claim when the defendant allegedly made misrepresentations through phone calls to the 9 We discuss appellants’ derivative denuding claims against Jason below. 10 “[T]he actions of an agent may establish minimum contacts over a principal.” McFadin v. Gerber, 587 F.3d 753, 761 (5th Cir. 2009), cert. denied, 562 U.S. 827 (2010).	1	1
Charles Trois v. Apple Tree Auction Center, Inc, egreen ca5 · 2018 · cited in 1 Texas opinions naming this issue, 2018–2018 1 sentence 2018See Guidry, 188 F.3d at 628 ; Searcy, 496 S.W.3d at 67 ; see also Trois v. Apple Tree Auction Ctr., 882 F.3d 485 , 487–88, 490–91 (5th Cir. 2018) (recognizing the existence of specific jurisdiction over an Ohio defendant for a fraud claim when the defendant allegedly made misrepresentations through phone calls to the 9 We discuss appellants’ derivative denuding claims against Jason below. 10 “[T]he actions of an agent may establish minimum contacts over a principal.” McFadin v. Gerber, 587 F.3d 753, 761 (5th Cir. 2009), cert. denied, 562 U.S. 827 (2010).	1	1
Placer Dome, Inc. v. Provincial Government of Marinduque, Republic of the Philippinesgreen scotus · 2010 · cited in 1 Texas opinions naming this issue, 2018–2018 1 sentence 2018See Guidry, 188 F.3d at 628 ; Searcy, 496 S.W.3d at 67 ; see also Trois v. Apple Tree Auction Ctr., 882 F.3d 485 , 487–88, 490–91 (5th Cir. 2018) (recognizing the existence of specific jurisdiction over an Ohio defendant for a fraud claim when the defendant allegedly made misrepresentations through phone calls to the 9 We discuss appellants’ derivative denuding claims against Jason below. 10 “[T]he actions of an agent may establish minimum contacts over a principal.” McFadin v. Gerber, 587 F.3d 753, 761 (5th Cir. 2009), cert. denied, 562 U.S. 827 (2010).	1	1
McFadin v. Gerbergreen ca5 · 2009 · cited in 1 Texas opinions naming this issue, 2018–2018 1 sentence 2018See Guidry, 188 F.3d at 628 ; Searcy, 496 S.W.3d at 67 ; see also Trois v. Apple Tree Auction Ctr., 882 F.3d 485 , 487–88, 490–91 (5th Cir. 2018) (recognizing the existence of specific jurisdiction over an Ohio defendant for a fraud claim when the defendant allegedly made misrepresentations through phone calls to the 9 We discuss appellants’ derivative denuding claims against Jason below. 10 “[T]he actions of an agent may establish minimum contacts over a principal.” McFadin v. Gerber, 587 F.3d 753, 761 (5th Cir. 2009), cert. denied, 562 U.S. 827 (2010).	1	1
Thomas Charles Taborelli v. Robert Brown, Robert F. Bort, Tex Marchal, Eugenia Skobrakgreen ca6 · 1987 · cited in 1 Texas opinions naming this issue, 1992–1992 1 sentence 1992See Superintendent of Ins. v. Baker & Hostetler, 668 F.Supp. 1057, 1061 (N.D.Ohio 1986), aff'd, 826 F.2d 1065 (6th Cir.1987) (when New York receiver brought suit in Ohio to marshall assets of estate of insolvent New York insurance company, Ohio defendant’s counterclaim was barred by the receivership court’s injunction under full faith and credit).	1	1
Superintendent of Insurance v. Baker & Hostetlergreen ohnd · 1986 · cited in 1 Texas opinions naming this issue, 1992–1992 1 sentence 1992See Superintendent of Ins. v. Baker & Hostetler, 668 F.Supp. 1057, 1061 (N.D.Ohio 1986), aff'd, 826 F.2d 1065 (6th Cir.1987) (when New York receiver brought suit in Ohio to marshall assets of estate of insolvent New York insurance company, Ohio defendant’s counterclaim was barred by the receivership court’s injunction under full faith and credit).	1	1

Distinguished, questioned or overruled (1)

Case	Negative	Cited
Hawes v. Custom Canners, Inc.green gactapp · 1970 · cited in 2 Texas opinions naming this issue, 1996–1996 2 sentences 1996But see Hawes v. Custom Canners, Inc., 121 Ga.App. 203 , 173 S.E.2d 400 (1970); Webster Brick Co. v. Department of Taxation, 219 Va. 81 , 245 S.E.2d 252 (1978). 1996But see Hawes v. Custom Canners, Inc., 121 Ga.App. 203 , 173 S.E.2d 400 (1970); Webster Brick Co. v. Department of Taxation, 219 Va. 81 , 245 S.E.2d 252 (1978).	2	2

Also cited on this issue (7)

Case	Cited	Years
Schenley Distillers, Inc. v. Commonwealth Ex Rel. Luckett green kyctapphigh · 1971 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett , 467 S.W.2d 598 (Ky. Ct. App. 1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation , 266 N.E.2d 284, 290 (Mass. 1971) ("used directly") (stating that "[w]e think the Ohio cases are too restrictive"); Floyd Charcoal Co. v. Director of Revenue , 599 S.W.2d 173, 177 (Mo. 1980) ("used directly") (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem"); Niagara Mohawk Power Corp. v. Wanamaker , 144 N.Y.S.2d 458, 461-62 (App. Div. 1955) ("use[d] . . . directly and exclusively") (stating that "`directly a	2	1996–1996
MATTER OF NIAGARA MOHAWK POWER CORP. v. Wanamaker green ny · 1956 2 sentences 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire 1996Luckett, 467 S.W.2d 598 (Ky.Ct.App.1971); Courier Citizen Co. v. Commissioner of Corps. & Taxation, 358 Mass. 563 , 266 N.E.2d 284, 290 (1971) ("used directly”) (stating that "[w]e think the Ohio cases are too restrictive”); Floyd Charcoal Co. v. Director of Revenue, 599 S.W.2d 173, 177 (Mo.1980) ("used directly”) (stating that "[t]he Ohio rule has been considered too restrictive by other courts which have been presented with a similar problem”); Niagara Mohawk Power Corp. v. Wanamaker, 286 A.D. 446 , 144 N.Y.S.2d 458, 461-62 (1955) (“use[d] ... directly and exclusively”) (stating that “ ‘dire	2	1996–1996
Webster Brick Co. v. Department of Taxation green va · 1978 2 sentences 1996But see Hawes v. Custom Canners, Inc., 121 Ga.App. 203 , 173 S.E.2d 400 (1970); Webster Brick Co. v. Department of Taxation, 219 Va. 81 , 245 S.E.2d 252 (1978). 1996But see Hawes v. Custom Canners, Inc., 121 Ga.App. 203 , 173 S.E.2d 400 (1970); Webster Brick Co. v. Department of Taxation, 219 Va. 81 , 245 S.E.2d 252 (1978).	2	1996–1996
Jason R. Searcy, as Trustee of the Exempt Assets Trust v. Parex Resources, Inc. green tex · 2016 1 sentence 2018See Guidry, 188 F.3d at 628 ; Searcy, 496 S.W.3d at 67 ; see also Trois v. Apple Tree Auction Ctr., 882 F.3d 485 , 487–88, 490–91 (5th Cir. 2018) (recognizing the existence of specific jurisdiction over an Ohio defendant for a fraud claim when the defendant allegedly made misrepresentations through phone calls to the 9 We discuss appellants’ derivative denuding claims against Jason below. 10 “[T]he actions of an agent may establish minimum contacts over a principal.” McFadin v. Gerber, 587 F.3d 753, 761 (5th Cir. 2009), cert. denied, 562 U.S. 827 (2010).	1	2018–2018
City of Maryville v. Farmers Trust Co. neutral moctapp · 1931 1 sentence 2004The State had correctly framed the choice of law rule in such a situation: if evidence is privileged under the law of the state with the most significant relationship to the communication, but is not privileged under the law of the forum, it should be admitted "unless there is some special reason why the forum policy favoring admission should not be given effect." Gonzalez , 45 S.W.2d at 103 (quoting Restatement (Second) of Conflict of Laws §139 (1971)).	1	2004–2004
Zauderer v. Office of Disciplinary Counsel of the Supreme Court of Ohio green scotus · 1985 2 sentences 1995We note that the United States Supreme Court in Zauderer , note 15, 471 U.S. at 653 , 105 S.Ct. at 2283 , 85 L.Ed.2d at 673-674 , addressed the potential for such a problem in the Ohio rule which appears to be less informative and directive than the rule before us. 6 .Complaints were filed by Elizabeth Childress, Kevin Standifer and Rene Sandoval, as well as by the State Bar of Texas. 1995We note that the United States Supreme Court in Zauderer , note 15, 471 U.S. at 653 , 105 S.Ct. at 2283 , 85 L.Ed.2d at 673-674 , addressed the potential for such a problem in the Ohio rule which appears to be less informative and directive than the rule before us. 6 .Complaints were filed by Elizabeth Childress, Kevin Standifer and Rene Sandoval, as well as by the State Bar of Texas.	1	1995–1995
Russell v. Todd green scotus · 1940 2 sentences 1945The full import of the phrase, “an adversary suit in equity against the stockholders wherever they may be found,” is clearly stated by the same writer, Mr. Justice Stone, in his later opinion in Russell v. Todd, 309 U. S. 280 , 84 L. 1945The full import of the phrase, “an adversary suit in equity against the stockholders wherever they may be found,” is clearly stated by the same writer, Mr. Justice Stone, in his later opinion in Russell v. Todd, 309 U. S. 280 , 84 L.	1	1945–1945

Where else courts name it

OH 305 (1875–2026) TX 7 (1945–2018) PA 6 (1940–2024) KY 5 (1961–2016) HI 5 (1964–2019) CA 5 (1970–2019) NY 5 (1959–2006) IL 4 (1981–2025) MO 4 (1904–2009) MI 4 (1940–2018) MD 4 (1961–2019) MS 4 (1989–1997) WA 3 (1955–1986) WI 3 (1926–1999) OR 3 (1898–1935) NE 3 (1908–1990) IA 3 (1973–1993) NC 2 (1979–2001) DE 2 (2019–2023) NJ 2 (1958–2000) AK 2 (1983–1990) CO 2 (1979–1998) MN 2 (2004–2006) WV 2 (1978–1997) TN 2 (1954–2018)

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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