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6 Ohio opinions name it 2 courts 1998–2026 2 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 |
|---|---|---|
State v. Schiebelgreen1 sentence2026This court, in an entry dated September 24, 2025, reminded Hasan that a “dispute as to the accuracy of the trial court record is to be settled by the trial court pursuant to App.R. 9(E).” Quoting State v. Schiebel, 55 Ohio St.3d 71, 92 (1990), it further noted that “[i]t is not within our authority to ‘resolve disputes about the trial court’s record in the course of an appeal.’” As discussed above, Hasan did thereafter file a motion with the trial court with respect to certain exhibits that she had in fact used at trial, and the trial court granted her motion to supplement the record by order | 1 | 1 |
Bilikam v. Bilikamgreen1 sentence2018See Bilikam at 305, 441 N.E.2d 845 . {¶ 22} Moreover, Ms. Boldman, as an adverse party, offered Uncle Bill's statements to establish his donative intent and thereby to defend against the concealment claim. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Ohio. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
In Re Estate of Popp
green
2 sentences2009In all cases, except when the person found guilty is the fiduciary, the probate court shall forthwith render judgment in favor of the fiduciary or if there is no fiduciary in this state, the probate court shall render judgment in favor of the state, against the person found guilty, for the amount of the moneys or the value of the chattels or choses in action concealed, embezzled, conveyed away, or held in possession, together with ten per cent penalty and all costs of such proceedings or complaint; except that such judgment shall be reduced to the extent of the value of any thing specifically 2009In all cases, except when the person found guilty is the fiduciary, the probate court shall forthwith render judgment in favor of the fiduciary or if there is no fiduciary in this state, the probate court shall render judgment in favor of the state, against the person found guilty, for the amount of the moneys or the value of the chattels or choses in action concealed, embezzled, conveyed away, or held in possession, together with ten per cent penalty and all costs of such proceedings or complaint; except that such judgment shall be reduced to the extent of the value of any thing specifically | 2 | 1998–2009 |
Bank of Am., N.A. v. Kuchta (Slip Opinion)
green
1 sentence2026Assignments of Error and Analysis {¶38} Appellant’s first assignment of error states: “The Trial Court committed prejudicial error when it found Appellant guilty of concealment.” {¶39} We first consider whether the trial court had subject matter jurisdiction to reach the merits of Appellee’s concealment claim. {¶40} “The general term ‘jurisdiction’ can be used to connote several distinct concepts, including jurisdiction over the subject matter, jurisdiction over the person, and jurisdiction over a particular case.” Bank of Am., N.A. v. Kuchta, 2014-Ohio-4275 , ¶ 18. | 1 | 2026–2026 |
Goldberg v. Maloney
green
2 sentences2016He maintains that certain items should not be considered assets of the estate based on the determinations of the tax authorities. {¶ 14} However, the probate court does not have a tax matter before it but, rather, a concealment claim, over which the probate court has jurisdiction to determine title of allegedly concealed assets. “[Concealment actions under R.C. 2109.50 and 2109.52 could be applicable to recover certain assets wrongfully concealed, embezzled, or conveyed away before the creation of the estate.” (Emphasis deleted.) Goldberg v. Maloney, 111 Ohio St.3d 211 , 2006-Ohio-5485 , 855 N 2016He maintains that certain items should not be considered assets of the estate based on the determinations of the tax authorities. {¶ 14} However, the probate court does not have a tax matter before it but, rather, a concealment claim, over which the probate court has jurisdiction to determine title of allegedly concealed assets. “[Concealment actions under R.C. 2109.50 and 2109.52 could be applicable to recover certain assets wrongfully concealed, embezzled, or conveyed away before the creation of the estate.” (Emphasis deleted.) Goldberg v. Maloney, 111 Ohio St.3d 211 , 2006-Ohio-5485 , 855 N | 1 | 2016–2016 |
Rinehart v. Bank One, Columbus, N.A.
green
2 sentences2009In all cases, except when the person found guilty is the fiduciary, the probate court shall forthwith render judgment in favor of the fiduciary or if there is no fiduciary in this state, the probate court shall render judgment in favor of the state, against the person found guilty, for the amount of the moneys or the value of the chattels or choses in action concealed, embezzled, conveyed away, or held in possession, together with ten per cent penalty and all costs of such proceedings or complaint; except that such judgment shall be reduced to the extent of the value of any thing specifically 2009In all cases, except when the person found guilty is the fiduciary, the probate court shall forthwith render judgment in favor of the fiduciary or if there is no fiduciary in this state, the probate court shall render judgment in favor of the state, against the person found guilty, for the amount of the moneys or the value of the chattels or choses in action concealed, embezzled, conveyed away, or held in possession, together with ten per cent penalty and all costs of such proceedings or complaint; except that such judgment shall be reduced to the extent of the value of any thing specifically | 1 | 2009–2009 |
In Re Estate of Woods
green
2 sentences2009In the alternative, Butler argues that the complaint states a claim for breach of contract, which is also amenable to arbitration, and for which the concealment statute is not to be used as a substitute, in order “to collect a debt, obtain an accounting or adjudicate rights under a contract.” In re Estate of Woods (1959), 110 Ohio App. 277, 285 , 11 O.O.2d 302 , 167 N.E.2d 122 . {¶ 13} Thus, Butler’s third assignment of error requires us to determine the nature of the claim set forth in the complaint and whether the probate court correctly analyzed it as a concealment claim. 2009In the alternative, Butler argues that the complaint states a claim for breach of contract, which is also amenable to arbitration, and for which the concealment statute is not to be used as a substitute, in order “to collect a debt, obtain an accounting or adjudicate rights under a contract.” In re Estate of Woods (1959), 110 Ohio App. 277, 285 , 11 O.O.2d 302 , 167 N.E.2d 122 . {¶ 13} Thus, Butler’s third assignment of error requires us to determine the nature of the claim set forth in the complaint and whether the probate court correctly analyzed it as a concealment claim. | 1 | 2009–2009 |
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.