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50 Ohio opinions name it 4 courts 1901–2026 6 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 |
|---|---|---|
Ohio State Board of Pharmacy v. Frantzgreen2 sentences2025Oil Co. v. Orteca, 63 Ohio St.2d 295, 299 (1980) (explaining the doctrine of equitable estoppel “precludes a party from asserting certain facts where the party, by his conduct, has induced another to change his [or her] position in good faith reliance upon that conduct”). {¶ 39} Implicit in this exception “is the principle that ‘[t]he purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’ ” Archdiocese of Cincinnati at ¶ 7 , quoting Ohio State Bd. of Pharmacy v. Frantz, 51 Ohio St.3d 143, 145 (1990). 2022Under the doctrine of equitable estoppel, “‘a representation of past or existing fact made to a party who relies upon it reasonably may not thereafter be denied by the party making the representation if permitting the denial would result in injury or damage to the party who so relies.’” Hortman v. Miamisburg, 110 Ohio St.3d 194 , 2006-Ohio-4251 , 852 N.E.2d 716, ¶ 20 , quoting 4 Richard A. Lord, Williston on Contracts, Section 8:3, at 28-31 (4th Ed.1992). “‘The purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’” Doe v. Archdiocese of C | 3 | 7 |
State ex rel. Cities Service Oil Co. v. Ortecagreen2 sentences2025Oil Co. v. Orteca, 63 Ohio St.2d 295, 299 (1980) (explaining the doctrine of equitable estoppel “precludes a party from asserting certain facts where the party, by his conduct, has induced another to change his [or her] position in good faith reliance upon that conduct”). {¶ 39} Implicit in this exception “is the principle that ‘[t]he purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’ ” Archdiocese of Cincinnati at ¶ 7 , quoting Ohio State Bd. of Pharmacy v. Frantz, 51 Ohio St.3d 143, 145 (1990). 2018Oil Co. v. Orteca, 63 Ohio St.2d 295, 299 (1980). | 2 | 2 |
Helman v. Epl Prolong, Inc.green2 sentences2018Appellants assert that equitable estoppel is applicable based on representations made by appellees regarding the distribution of assets under Ohio's anti-lapse statute, i.e., representations by Freed and Panitch that the assets of the Greenawalt Estate would be distributed to all ten nieces and nephews. {¶ 34} The doctrine of equitable estoppel "precludes a party from asserting certain facts where the party, by his conduct, has induced another to change his position in good- faith reliance upon that conduct." Helman v. EPL Prolong, Inc., 139 Ohio App.3d 231, 245-46 (7th Dist.2000), citing Stat 2006While hardly perfect, this meets the minimal criteria of Civ.R. 56(E). 2 {¶ 27} JRC further contends that Samsel’s reliance on the statute of limitations is defeated by the doctrine of equitable estoppel. {¶ 28} “ ‘A prima facie case for equitable estoppel requires a plaintiff to prove four elements: (1) that the defendant made a factual misrepresentation; (2) that it is misleading; (3) [that it induced] actual reliance which is reasonable and in good faith; and (4) [that the reliance caused] detriment to the relying party.’ ” Helman v. EPL Prolong, Inc. (2000), 139 Ohio App.3d 231, 246 , 743 | 1 | 4 |
State ex rel. Polo v. Cuyahoga County Boardgreen1 sentence2026Bd. of Elections, 74 Ohio St.3d 143, 145 (1995); accord Blankenship v. Blackwell, 2004-Ohio-5596 , ¶ 19. {¶ 78} Like the doctrine of equitable estoppel, the equitable doctrine of laches may not be applied to prevent local governments from enforcing a zoning regulation. | 1 | 1 |
Cain v. Panitchgreen1 sentence2025“In this context, ‘courts have held that when applied to a limitations No. 25AP-128 13 defense, a plaintiff must show that the defendant misrepresented the length of the limitations period, or promised a better settlement if the plaintiff did not bring suit.’ ” (Emphasis added.) Cain v. Panitch, 2018-Ohio-1595, ¶ 35 (10th Dist.), quoting JRC Holdings, Inc. v. Samsel Servs. | 1 | 1 |
Kim Ngo v. Bmw of North America, LLCgreen1 sentence2023L.L.C., 23 F.4th 942, 949 (9th Cir.2022), quoting Goldman v. KPMG L.L.P., 173 Cal.App.4th 209, 220 (2009) (the doctrine of equitable estoppel “prevents a plaintiff from having it ‘both ways’ by seeking to hold a non-signatory [defendant] liable for obligations ‘imposed by [an] agreement,’ while at the same time ‘repudiating the arbitration clause of that very agreement’ ” because the defendant is a non-signatory); Muecke Co., Inc. v. CVS Caremark Corp., 615 Fed.Appx. 837, 842 (5th Cir.2015) (“Because the plaintiffs are suing the defendants as if the defendants were parties to the contract, the | 1 | 1 |
Goldman v. KPMG, LLPgreen1 sentence2023L.L.C., 23 F.4th 942, 949 (9th Cir.2022), quoting Goldman v. KPMG L.L.P., 173 Cal.App.4th 209, 220 (2009) (the doctrine of equitable estoppel “prevents a plaintiff from having it ‘both ways’ by seeking to hold a non-signatory [defendant] liable for obligations ‘imposed by [an] agreement,’ while at the same time ‘repudiating the arbitration clause of that very agreement’ ” because the defendant is a non-signatory); Muecke Co., Inc. v. CVS Caremark Corp., 615 Fed.Appx. 837, 842 (5th Cir.2015) (“Because the plaintiffs are suing the defendants as if the defendants were parties to the contract, the | 1 | 1 |
Muecke Company, Incorporated v. CVS Caremargreen1 sentence2023L.L.C., 23 F.4th 942, 949 (9th Cir.2022), quoting Goldman v. KPMG L.L.P., 173 Cal.App.4th 209, 220 (2009) (the doctrine of equitable estoppel “prevents a plaintiff from having it ‘both ways’ by seeking to hold a non-signatory [defendant] liable for obligations ‘imposed by [an] agreement,’ while at the same time ‘repudiating the arbitration clause of that very agreement’ ” because the defendant is a non-signatory); Muecke Co., Inc. v. CVS Caremark Corp., 615 Fed.Appx. 837, 842 (5th Cir.2015) (“Because the plaintiffs are suing the defendants as if the defendants were parties to the contract, the | 1 | 1 |
Gore v. Mohamodgreen1 sentence2022Gore at ¶ 11 (no allegations in the complaint supporting the application of the equitable estoppel doctrine); Omobien v. Flinn, 9th Dist. | 1 | 1 |
Engler v. Adjutant Gen.green1 sentence2022No. 17AP-814, 2018-Ohio-2273, ¶ 10-11 (no allegations in the complaint supporting the application of the equitable estoppel doctrine); Rankin v. Rosolowski, 8th Dist. | 1 | 1 |
Omobien v. Flinngreen1 sentence2022No. C.A. 29841, 2021-Ohio-2096, ¶ 8-11 (no allegations in the complaint supporting the application of the savings statute); Engler v. Adjutant Gen. of Ohio, 10th Dist. | 1 | 1 |
Jefferson Place Condominium Assn. v. Naplesgreen1 sentence2020Butler No. CA2001-02-047, 2001 Ohio App. LEXIS 5100 , *5 (Nov. 13, 2001), citing Jefferson Place Condominium Assn. v. Naples, 125 Ohio App. 3d 394, 401 (7th Dist.1998). {¶ 13} In so holding, we note that Gray did not specifically raise equitable estoppel as a defense before the trial court. | 1 | 1 |
Javitch v. First Union Securities, Inc.green1 sentence2016Further, Appellees argue that DRI cannot separately pursue its claims against Scherzer because E&Y is a necessary and indispensable party to those claims. {¶23} As the Magistrate’s decision notes, the “application of equitable estoppel is warranted . . . when the signatory [to the contract containing the arbitration clause] raises allegations of . . . substantially interdependent and concerted misconduct by both the nonsignatory and one or more of the signatories to the contract.” (Internal quotations and citations omitted.) Liedtke v. Frank, 437 F.Supp.2d 696, 699 (N.D.Ohio 2006); see Javitch | 1 | 1 |
Liedtke v. Frankgreen1 sentence2016Further, Appellees argue that DRI cannot separately pursue its claims against Scherzer because E&Y is a necessary and indispensable party to those claims. {¶23} As the Magistrate’s decision notes, the “application of equitable estoppel is warranted . . . when the signatory [to the contract containing the arbitration clause] raises allegations of . . . substantially interdependent and concerted misconduct by both the nonsignatory and one or more of the signatories to the contract.” (Internal quotations and citations omitted.) Liedtke v. Frank, 437 F.Supp.2d 696, 699 (N.D.Ohio 2006); see Javitch | 1 | 1 |
Cohen v. Estate of Cohengreen1 sentence2012Cohen, 23 Ohio St.3d at 91 (1986). | 1 | 1 |
| Metalworking MacHinery Co. v. Fabco, Inc.green | 1 | 1 |
| Welsh v. Tontigreen | 1 | 1 |
| Springdale Plant Farm, Inc. v. Lindleygreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Doe v. Archdiocese of Cincinnati
green
2 sentences2022Under the doctrine of equitable estoppel, “‘a representation of past or existing fact made to a party who relies upon it reasonably may not thereafter be denied by the party making the representation if permitting the denial would result in injury or damage to the party who so relies.’” Hortman v. Miamisburg, 110 Ohio St.3d 194 , 2006-Ohio-4251 , 852 N.E.2d 716, ¶ 20 , quoting 4 Richard A. Lord, Williston on Contracts, Section 8:3, at 28-31 (4th Ed.1992). “‘The purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’” Doe v. Archdiocese of C 2022Under the doctrine of equitable estoppel, “‘a representation of past or existing fact made to a party who relies upon it reasonably may not thereafter be denied by the party making the representation if permitting the denial would result in injury or damage to the party who so relies.’” Hortman v. Miamisburg, 110 Ohio St.3d 194 , 2006-Ohio-4251 , 852 N.E.2d 716, ¶ 20 , quoting 4 Richard A. Lord, Williston on Contracts, Section 8:3, at 28-31 (4th Ed.1992). “‘The purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’” Doe v. Archdiocese of C | 4 | 2018–2022 |
Bank One Trust Co. v. Lacour
green
2 sentences2010Bank One Trust Co., N.A. v. LaCour (1999), 131 Ohio App.3d 48, 55 , 721 N.E.2d 491 . 2010Bank One Trust Co., N.A. v. LaCour (1999), 131 Ohio App.3d 48, 55 , 721 N.E.2d 491 . | 4 | 2002–2010 |
Hortman v. City of Miamisburg
green
2 sentences2022Under the doctrine of equitable estoppel, “‘a representation of past or existing fact made to a party who relies upon it reasonably may not thereafter be denied by the party making the representation if permitting the denial would result in injury or damage to the party who so relies.’” Hortman v. Miamisburg, 110 Ohio St.3d 194 , 2006-Ohio-4251 , 852 N.E.2d 716, ¶ 20 , quoting 4 Richard A. Lord, Williston on Contracts, Section 8:3, at 28-31 (4th Ed.1992). “‘The purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’” Doe v. Archdiocese of C 2022Under the doctrine of equitable estoppel, “‘a representation of past or existing fact made to a party who relies upon it reasonably may not thereafter be denied by the party making the representation if permitting the denial would result in injury or damage to the party who so relies.’” Hortman v. Miamisburg, 110 Ohio St.3d 194 , 2006-Ohio-4251 , 852 N.E.2d 716, ¶ 20 , quoting 4 Richard A. Lord, Williston on Contracts, Section 8:3, at 28-31 (4th Ed.1992). “‘The purpose of equitable estoppel is to prevent actual or constructive fraud and to promote the ends of justice.’” Doe v. Archdiocese of C | 3 | 2020–2022 |
Allen v. Andersen Windows, Inc.
green
2 sentences2018No. 2000CA00311 (Apr. 30, 2001), in which that court "rejected the application of equitable estoppel when the alleged representations related to the merits of plaintiff's claims and were 'in no way related to misrepresentations concerning the statute of limitations or a promise of settlement.' " Lottridge at ¶ 21, quoting Kegg. {¶ 40} This court's decision in Lottridge also cited with approval a federal decision, Allen v. Andersen Windows, Inc., 913 F.Supp.2d 490 (S.D.Ohio 2012), in which that court construed Ohio law with respect to the doctrine of equitable estoppel. 2018Id., quoting Kegg. {¶ 38} Similarly, in the instant case, the identical purported misrepresentations by appellees (i.e., that the Greenawalt estate assets were required to be divided among all ten nieces and nephews), while related to the merits of the claim, are " 'in no way related to misrepresentations concerning the statute of limitations.' " Accordingly, we find no error by the trial court in failing to apply the doctrine of equitable estoppel. {¶ 39} Based on this court's de novo review, we conclude the trial court properly granted summary judgment in favor of appellees on appellants' cl | 2 | 2018–2018 |
Gerig v. Kahn
green
2 sentences2017Gerig v. Kahn, 95 Ohio St.3d 478 , 2002-Ohio-2581, ¶ 19 . 2006Gerig v. Kahn, 95 Ohio St.3d 478 , 2002-Ohio-2581 , at ¶ 19 . | 2 | 2006–2017 |
Gerig v. Kahn
green
2 sentences2017Gerig v. Kahn, 95 Ohio St.3d 478 , 2002-Ohio-2581, ¶ 19 . 2006Gerig v. Kahn, 95 Ohio St.3d 478 , 2002-Ohio-2581 , at ¶ 19 . | 2 | 2006–2017 |
Doe v. Blue cross/blue Shield of Ohio
green
2 sentences2006While hardly perfect, this meets the minimal criteria of Civ.R. 56(E). 2 {¶ 27} JRC further contends that Samsel’s reliance on the statute of limitations is defeated by the doctrine of equitable estoppel. {¶ 28} “ ‘A prima facie case for equitable estoppel requires a plaintiff to prove four elements: (1) that the defendant made a factual misrepresentation; (2) that it is misleading; (3) [that it induced] actual reliance which is reasonable and in good faith; and (4) [that the reliance caused] detriment to the relying party.’ ” Helman v. EPL Prolong, Inc. (2000), 139 Ohio App.3d 231, 246 , 743 2006While hardly perfect, this meets the minimal criteria of Civ.R. 56(E). 2 {¶ 27} JRC further contends that Samsel’s reliance on the statute of limitations is defeated by the doctrine of equitable estoppel. {¶ 28} “ ‘A prima facie case for equitable estoppel requires a plaintiff to prove four elements: (1) that the defendant made a factual misrepresentation; (2) that it is misleading; (3) [that it induced] actual reliance which is reasonable and in good faith; and (4) [that the reliance caused] detriment to the relying party.’ ” Helman v. EPL Prolong, Inc. (2000), 139 Ohio App.3d 231, 246 , 743 | 2 | 2002–2006 |
Freedom Ford, Inc. v. Sun Bank & Trust Co. (In Re Freedom Ford, Inc.)
green
2 sentences2004Auto Ctr., Inc. (N.D.Ohio 1991), 130 B.R. 247 ; Matter of Freedom Ford, Inc. (M.D.Fla. 1992), 140 B.R. 585 ." Bruck Mfg. 1992Auto Ctr., Inc. (N.D.Ohio 1991), 130 B.R. 247 ; Matter of Freedom Ford, Inc. (M.D.Fla.1992), 140 B.R. 585 . | 2 | 1992–2004 |
Ohio, Department of Taxation v. H.R.P. Auto Center, Inc. (In Re H.R.P. Auto Center, Inc.)
green
2 sentences2004Auto Ctr., Inc. (N.D.Ohio 1991), 130 B.R. 247 ; Matter of Freedom Ford, Inc. (M.D.Fla. 1992), 140 B.R. 585 ." Bruck Mfg. 1992Auto Ctr., Inc. (N.D.Ohio 1991), 130 B.R. 247 ; Matter of Freedom Ford, Inc. (M.D.Fla.1992), 140 B.R. 585 . | 2 | 1992–2004 |
Pate v. Elliott
green
2 sentences2004Williams Co. (1969), 17 Ohio Misc. 219 . {¶ 75} The common law doctrine of equitable estoppel, if it would apply in this case, is described by the court of appeals in Pate v. Elliot (1978), 61 Ohio App.2d 144 , 146-147, 15 O.O.3d 275 , 400 N.E.2d 910 , as follows: [ Ogden v. Ogden (1854), 4 Ohio St. 182 , 195 ] merely states a basic tenet of American property law: a purchaser of property acquires only as sound a title as was held by the seller. 2004Williams Co. (1969), 17 Ohio Misc. 219 . {¶ 75} The common law doctrine of equitable estoppel, if it would apply in this case, is described by the court of appeals in Pate v. Elliot (1978), 61 Ohio App.2d 144 , 146-147, 15 O.O.3d 275 , 400 N.E.2d 910 , as follows: [ Ogden v. Ogden (1854), 4 Ohio St. 182 , 195 ] merely states a basic tenet of American property law: a purchaser of property acquires only as sound a title as was held by the seller. | 2 | 1998–2004 |
Whiteco Metrocom, Inc. v. City of Columbus
green
2 sentences2002Id. "[A] municipality will be bound only by the representations authorized to be made by its officers and agents." Id. 2002Id. "[A] municipality will be bound only by the representations authorized to be made by its officers and agents." Id. | 2 | 1999–2002 |
Ford v. Industrial Commission
green
1 sentence2023Instead, it is “determined by the statutes that are applicable.” Id. at 5 . {¶44} Further, a mistake does not provide a basis for the application of the doctrine of equitable estoppel. | 1 | 2023–2023 |
Chubb v. Ohio Bureau of Workers' Compensation
green
1 sentence2019The doctrine of equitable estoppel “‘prevents relief when one party induces another to believe certain facts exist and the other party changes his position in reasonable reliance on those facts to his detriment.’” Id., quoting State ex rel. | 1 | 2019–2019 |
Ruther v. Kaiser
green
2 sentences2019This demonstrates that the General Assembly intentionally chose not to create a fraud exception or an equitable-estoppel exception for medical claims. {¶12} “The General Assembly has the right to define the contours of a cause of action.” Ruther v. Kaiser, 134 Ohio St.3d 408 , 2012-Ohio-5686 , 983 N.E.2d 291, ¶ 26 . 5 OHIO FIRST DISTRICT COURT OF APPEALS By enacting R.C. 2305.113(C), the General Assembly chose up to four years for an action on a medical claim to arise. 2019This demonstrates that the General Assembly intentionally chose not to create a fraud exception or an equitable-estoppel exception for medical claims. {¶12} “The General Assembly has the right to define the contours of a cause of action.” Ruther v. Kaiser, 134 Ohio St.3d 408 , 2012-Ohio-5686 , 983 N.E.2d 291, ¶ 26 . 5 OHIO FIRST DISTRICT COURT OF APPEALS By enacting R.C. 2305.113(C), the General Assembly chose up to four years for an action on a medical claim to arise. | 1 | 2019–2019 |
Xtreme Elements, L.L.C. v. Foti Contracting, L.L.C.
neutral
1 sentence2018Lake No. 2016-L-043, 2017-Ohio-254 , 2017 WL 283382 , ¶ 25. | 1 | 2018–2018 |
| Perkins v. Falke & Dunphy, L.L.C. green | 1 | 2012–2012 |
| Abdallah v. Doctor's Assoc., Unpublished Decision (11-15-2007) neutral | 1 | 2008–2008 |
| Heskett v. Paulig green | 1 | 2007–2007 |
| Byrd v. Smith green | 1 | 2007–2007 |
| Chase Manhattan Bank v. Parker, Unpublished Decision (4-18-2005) green | 1 | 2007–2007 |
| Zumpano v. Quinn green | 1 | 2006–2006 |
| State v. Jones green | 1 | 2006–2006 |
| Gullatte v. Rion green | 1 | 2005–2005 |
| General Motors Acceptance Corp. v. Birkett L. Williams Co. green | 1 | 2004–2004 |
| Carr v. Michigan Real Estate Insurance Trust (In Re Michigan Real Estate Insurance Trust) green | 1 | 2004–2004 |
| Payne v. Cartee green | 1 | 2004–2004 |
| Walworth v. Bp Oil Co. green | 1 | 2002–2002 |
| Egan v. National Distillers & Chemical Corp. green | 1 | 2002–2002 |
| Village of Oakwood v. Clark Oil & Refining Corp. neutral | 1 | 2000–2000 |
| Halluer v. Emigh green | 1 | 2000–2000 |
| Griffith v. J.C. Penney Co. green | 1 | 1999–1999 |
| Lovejoy v. MacEk green | 1 | 1999–1999 |
| Bendix Autolite Corp. v. Midwesco Enterprises, Inc. green | 1 | 1999–1999 |
| State v. Payton green | 1 | 1999–1999 |
| Ruozzo v. Giles neutral | 1 | 1999–1999 |
| First Federal Savings & Loan Ass'n of Toledo v. Perry's Landing, Inc. green | 1 | 1996–1996 |
| Baxter, Trustee v. Village of Manchester green | 1 | 1994–1994 |
| Pedler v. Aetna Life Insurance green | 1 | 1990–1990 |
| City of Cincinnati v. Evans green | 1 | 1901–1901 |
| Lane v. Kennedy green | 1 | 1901–1901 |
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.