Ohio Revised Code

Ohio Rev. Code § 2917.21 (2026)

Telecommunications harassment

✓ current as of May 2026
Find cases: SyfertCases citing this section ORCcodes.ohio.gov (official) Justiaon Justia CornellLII Search CasesGoogle Scholar

(A) No person shall knowingly make or cause to be made a telecommunication, or knowingly permit a telecommunication to be made from a telecommunications device under the person's control, to another, if the caller does any of the following:

(1) Makes the telecommunication with purpose to harass, intimidate, or abuse any person at the premises to which the telecommunication is made, whether or not actual communication takes place between the caller and a recipient;

(2) Describes, suggests, requests, or proposes that the caller, the recipient of the telecommunication, or any other person engage in sexual activity, and the recipient or another person at the premises to which the telecommunication is made has requested, in a previous telecommunication or in the immediate telecommunication, that the caller not make a telecommunication to the recipient or to the premises to which the telecommunication is made;

(3) During the telecommunication, violates section 2903.21 of the Revised Code;

(4) Knowingly states to the recipient of the telecommunication that the caller intends to cause damage to or destroy public or private property, and the recipient, any member of the recipient's family, or any other person who resides at the premises to which the telecommunication is made owns, leases, resides, or works in, will at the time of the destruction or damaging be near or in, has the responsibility of protecting, or insures the property that will be destroyed or damaged;

(5) Knowingly makes the telecommunication to the recipient of the telecommunication, to another person at the premises to which the telecommunication is made, or to those premises, and the recipient or another person at those premises previously has told the caller not to make a telecommunication to those premises or to any persons at those premises;

(6) Knowingly makes any comment, request, suggestion, or proposal to the recipient of the telecommunication that is threatening, intimidating, menacing, coercive, or obscene with the intent to abuse, threaten, or harass the recipient;

(7) Without a lawful business purpose, knowingly interrupts the telecommunication service of any person;

(8) Without a lawful business purpose, knowingly transmits to any person, regardless of whether the telecommunication is heard in its entirety, any file, document, or other communication that prevents that person from using the person's telephone service or electronic communication device;

(9) Knowingly makes any false statement concerning the death, injury, illness, disfigurement, reputation, indecent conduct, or criminal conduct of the recipient of the telecommunication or family or household member of the recipient with purpose to abuse, threaten, intimidate, or harass the recipient;

(10) Knowingly incites another person through a telecommunication or other means to harass or participate in the harassment of a person;

(11) Knowingly alarms the recipient by making a telecommunication without a lawful purpose at an hour or hours known to be inconvenient to the recipient and in an offensive or repetitive manner.

(B)(1) No person shall make or cause to be made a telecommunication, or permit a telecommunication to be made from a telecommunications device under the person's control, with purpose to abuse, threaten, or harass another person.

(2) No person shall knowingly post a text or audio statement or an image on an internet web site or web page for the purpose of abusing, threatening, or harassing another person.

(C)(1) Whoever violates this section is guilty of telecommunications harassment.

(2) A violation of division (A)(1), (2), (3), (5), (6), (7), (8), (9), (10), or (11) or (B) of this section is a misdemeanor of the first degree on a first offense and a felony of the fifth degree on each subsequent offense.

(3) Except as otherwise provided in division (C)(3) of this section, a violation of division (A)(4) of this section is a misdemeanor of the first degree on a first offense and a felony of the fifth degree on each subsequent offense. If a violation of division (A)(4) of this section results in economic harm of one thousand dollars or more but less than seven thousand five hundred dollars, telecommunications harassment is a felony of the fifth degree. If a violation of division (A)(4) of this section results in economic harm of seven thousand five hundred dollars or more but less than one hundred fifty thousand dollars, telecommunications harassment is a felony of the fourth degree. If a violation of division (A)(4) of this section results in economic harm of one hundred fifty thousand dollars or more, telecommunications harassment is a felony of the third degree.

(D) No cause of action may be asserted in any court of this state against any provider of a telecommunications service, interactive computer service as defined in section 230 of Title 47 of the United States Code, or information service, or against any officer, employee, or agent of a telecommunication service, interactive computer service as defined in section 230 of Title 47 of the United States Code, or information service, for any injury, death, or loss to person or property that allegedly arises out of the provider's, officer's, employee's, or agent's provision of information, facilities, or assistance in accordance with the terms of a court order that is issued in relation to the investigation or prosecution of an alleged violation of this section. A provider of a telecommunications service, interactive computer service as defined in section 230 of Title 47 of the United States Code, or information service, or an officer, employee, or agent of a telecommunications service, interactive computer service as defined in section 230 of Title 47 of the United States Code, or information service, is immune from any civil or criminal liability for injury, death, or loss to person or property that allegedly arises out of the provider's, officer's, employee's, or agent's provision of information, facilities, or assistance in accordance with the terms of a court order that is issued in relation to the investigation or prosecution of an alleged violation of this section.

(E)(1) This section does not apply to a person solely because the person provided access or connection to or from an electronic method of remotely transferring information not under that person's control, including having provided capabilities that are incidental to providing access or connection to or from the electronic method of remotely transferring the information, and that do not include the creation of the content of the material that is the subject of the access or connection. In addition, any person providing access or connection to or from an electronic method of remotely transferring information not under that person's control shall not be liable for any action voluntarily taken in good faith to block the receipt or transmission through its service of any information that the person believes is, or will be sent, in violation of this section.

(2) Division (E)(1) of this section does not create an affirmative duty for any person providing access or connection to or from an electronic method of remotely transferring information not under that person's control to block the receipt or transmission through its service of any information that it believes is, or will be sent, in violation of this section except as otherwise provided by law.

(3) Division (E)(1) of this section does not apply to a person who conspires with a person actively involved in the creation or knowing distribution of material in violation of this section or who knowingly advertises the availability of material of that nature.

(4) A provider or user of an interactive computer service, as defined in section 230 of Title 47 of the United States Code, shall neither be treated as the publisher or speaker of any information provided by another information content provider, as defined in section 230 of Title 47 of the United States Code, nor held civilly or criminally liable for the creation or development of information provided by another information content provider, as defined in section 230 of Title 47 of the United States Code. Nothing in this division shall be construed to protect a person from liability to the extent that the person developed or created any content in violation of this section.

(F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable operator, or radio or television station, is gathering, processing, transmitting, compiling, editing, or disseminating information for the general public within the scope of the person's employment in that capacity or the person's contractual authority in that capacity.

(G) As used in this section:

(1) "Economic harm" means all direct, incidental, and consequential pecuniary harm suffered by a victim as a result of criminal conduct. "Economic harm" includes, but is not limited to, all of the following:

(a) All wages, salaries, or other compensation lost as a result of the criminal conduct;

(b) The cost of all wages, salaries, or other compensation paid to employees for time those employees are prevented from working as a result of the criminal conduct;

(c) The overhead costs incurred for the time that a business is shut down as a result of the criminal conduct;

(d) The loss of value to tangible or intangible property that was damaged as a result of the criminal conduct.

(2) "Caller" means the person described in division (A) of this section who makes or causes to be made a telecommunication or who permits a telecommunication to be made from a telecommunications device under that person's control.

(3) "Telecommunication" and "telecommunications device" have the same meanings as in section 2913.01 of the Revised Code.

(4) "Sexual activity" has the same meaning as in section 2907.01 of the Revised Code.

(5) "Family or household member" means any of the following:

(a) Any of the following who is residing or has resided with the recipient of the telecommunication against whom the act prohibited in division (A)(9) of this section is committed:

(i) A spouse, a person living as a spouse, or a former spouse of the recipient;

(ii) A parent, a foster parent, or a child of the recipient, or another person related by consanguinity or affinity to the recipient;

(iii) A parent or a child of a spouse, person living as a spouse, or former spouse of the recipient, or another person related by consanguinity or affinity to a spouse, person living as a spouse, or former spouse of the recipient.

(b) The natural parent of any child of whom the recipient of the telecommunication against whom the act prohibited in division (A)(9) of this section is committed is the other natural parent or is the putative other natural parent.

(6) "Person living as a spouse" means a person who is living or has lived with the recipient of the telecommunication against whom the act prohibited in division (A)(9) of this section is committed in a common law marital relationship, who otherwise is cohabiting with the recipient, or who otherwise has cohabited with the recipient within five years prior to the date of the alleged commission of the act in question.

(7) "Cable operator" has the same meaning as in section 1332.21 of the Revised Code.

(H) Nothing in this section prohibits a person from making a telecommunication to a debtor that is in compliance with the "Fair Debt Collection Practices Act," 91 Stat. 874 (1977), 15 U.S.C. 1692, as amended, or the "Telephone Consumer Protection Act," 105 Stat. 2395 (1991), 47 U.S.C. 227, as amended.

Notes of Decisions
Cited in 186 cases (79 in the last 5 years), 1982–2026 · leading case: Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018).
Sort: Relevance Newest Treatment
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). · cites it 61× “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
State v. Powell, 2020 Ohio 4283 (Ohio Ct. App. 2020). · cites it 4× “Haines included in his text message the language from R.C. 2917.21, the telecommunications-harassment statute.”
Delaware v. Boggs, 2018 Ohio 4677 (Ohio Ct. App. 2018). · cites it 21× “ons device under the person's control, to another, if the caller does any of the following: *** (5) Knowingly makes the telecommunication to the recipient of the telecommunication, to another person at the premises to which the telecommunication is made, or to those premises,…”
State v. Ham, 2017 Ohio 9189 (Ohio Ct. App. 2017). · cites it 5× “Specifically, the state requested that the telecommunications harassment charge be amended to reflect a violation of R.C. 2917.21(A)(5), which prohibits a person from continuing to make telecommunications after the recipient has told the caller to stop, instead of the (B)…”
State v. Gibbs, 730 N.E.2d 1027 (Ohio Ct. App. 1999). · cites it 11× “” In this assignment of error, appellant argues that R.C. 2917.21 is unconstitutionally overbroad, infringing upon her First Amendment right to free speech.”
In re C.W., 2019 Ohio 5262 (Ohio Ct. App. 2019). · cites it 8× “And, R.C. 2917.21(B) does not require more than a single transmission.”
State v. Wagner, 608 N.E.2d 852 (Ohio Ct. App. 1992). · cites it 6× “5: “The trial court erred in finding that repeated telephone calls to an answering machine constituted a violation of O.R.C. 2917.21.” We begin with the fifth assignment of error.”
State v. Ellison, 900 N.E.2d 228 (Ohio Ct. App. 2008). · cites it 5× “Ellison challenges her conviction for telecommunications harassment under R.C. 2917.21(B). We find merit to her appeal and reverse her conviction.”
Crenshaw v. Howard, 2022 Ohio 3914 (Ohio Ct. App. 2022). · cites it 5× “R.C. 2917.21 is a criminal statute. R.C. 2917.”
State v. Brentley, 2023 Ohio 2530 (Ohio Ct. App. 2023). · cites it 7× “As used under R.C. 2917.21(A), “‘[c]aller’” means the person * * * who makes or causes to be made a telecommunication or who permits a telecommunication to be made from a telecommunications device under that person’s control.”
State v. Shuck, 2020 Ohio 6989 (Ohio Ct. App. 2020). · cites it 9× “7 {¶15} Although none of the individual terms “abuse,” “threaten,” or “harass” have been statutorily defined within the meaning of R.C. 2917.21, “‘[t]he fact that the statute does not place legal definitions on each of these terms demonstrates that the General Assembly intended…”
State v. Salupo, 894 N.E.2d 746 (Ohio Ct. App. 2008). · cites it 4× “” A violation of R.C. 2917.21 can be a felony of the fifth degree only if it is a subsequent offense.”
Show all 186 citing cases →
— Ohio Rev. Code § 2917.21(1) — 1 case
State v. Perkins, 2025 Ohio 1576 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2917.21(A) — 7 cases
State v. Brentley, 2023 Ohio 2530 (Ohio Ct. App. 2023). “As used under R.C. 2917.21(A), “‘[c]aller’” means the person * * * who makes or causes to be made a telecommunication or who permits a telecommunication to be made from a telecommunications device under that person’s control.”
State v. White, 2023 Ohio 1103 (Ohio Ct. App. 2023).
State v. Farris, 2024 Ohio 868 (Ohio Ct. App. 2024).
State v. Harshbarger, 2010 Ohio 4413 (Ohio Ct. App. 2010).
State v. Hawks, 2025 Ohio 5407 (Ohio Ct. App. 2025).
— Ohio Rev. Code § 2917.21(A)(1) — 31 cases
State v. Brentley, 2023 Ohio 2530 (Ohio Ct. App. 2023). “As used under R.C. 2917.21(A), “‘[c]aller’” means the person * * * who makes or causes to be made a telecommunication or who permits a telecommunication to be made from a telecommunications device under that person’s control.”
State v. Goodman, 2024 Ohio 3353 (Ohio Ct. App. 2024).
In re M.A., 2016 Ohio 1161 (Ohio Ct. App. 2016).
State v. Baker, 2021 Ohio 272 (Ohio Ct. App. 2021).
Chagrin Falls v. Ptak, 2020 Ohio 5623 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2917.21(A)(1)(C)(2) — 1 case
State v. Clouser, 2023 Ohio 1425 (Ohio Ct. App. 2023).
— Ohio Rev. Code § 2917.21(A)(10) — 1 case
Talib v. Perkins Restaurant, 2026 Ohio 445 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2917.21(A)(2) — 2 cases
Hicks v. Faris (S.D. Ohio 2024).
State v. Eisele, 2014 Ohio 662 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2917.21(A)(3) — 17 cases
State v. Williams, 2021 Ohio 2032 (Ohio Ct. App. 2021).
In re Q.W., 2017 Ohio 8311 (Ohio Ct. App. 2017).
State v. Berkenstock, 2013 Ohio 4576 (Ohio Ct. App. 2013).
State v. Primous, 2020 Ohio 912 (Ohio Ct. App. 2020).
State v. Boczek, 2016 Ohio 5708 (Ohio Ct. App. 2016).
— Ohio Rev. Code § 2917.21(A)(4) — 2 cases
State v. Futrall, 2009 Ohio 5590 (Ohio 2009).
State v. Kister, 2014 Ohio 4596 (Ohio Ct. App. 2014).
— Ohio Rev. Code § 2917.21(A)(5) — 34 cases
Delaware v. Boggs, 2018 Ohio 4677 (Ohio Ct. App. 2018). “ons device under the person's control, to another, if the caller does any of the following: *** (5) Knowingly makes the telecommunication to the recipient of the telecommunication, to another person at the premises to which the telecommunication is made, or to those premises,…”
State v. Gibbs, 730 N.E.2d 1027 (Ohio Ct. App. 1999). “” In this assignment of error, appellant argues that R.C. 2917.21 is unconstitutionally overbroad, infringing upon her First Amendment right to free speech.”
State v. Ham, 2017 Ohio 9189 (Ohio Ct. App. 2017). “Specifically, the state requested that the telecommunications harassment charge be amended to reflect a violation of R.C. 2917.21(A)(5), which prohibits a person from continuing to make telecommunications after the recipient has told the caller to stop, instead of the (B)…”
State v. Erker, 2019 Ohio 3185 (Ohio Ct. App. 2019).
State v. DiSabato, 2019 Ohio 3542 (Ohio Ct. App. 2019).
— Ohio Rev. Code § 2917.21(A)(5)(C)(2) — 1 case
State v. Korbel, 2018 Ohio 1926 (Ohio Ct. App. 2018).
— Ohio Rev. Code § 2917.21(A)(6) — 7 cases
State v. Shuck, 2020 Ohio 6989 (Ohio Ct. App. 2020). “7 {¶15} Although none of the individual terms “abuse,” “threaten,” or “harass” have been statutorily defined within the meaning of R.C. 2917.21, “‘[t]he fact that the statute does not place legal definitions on each of these terms demonstrates that the General Assembly intended…”
State v. Rasawehr, 2020 Ohio 429 (Ohio Ct. App. 2020).
State v. Henry, 2023 Ohio 4020 (Ohio Ct. App. 2023).
Rasawehr v. Grey (N.D. Ohio 2024).
Hicks v. Faris (S.D. Ohio 2024).
— Ohio Rev. Code § 2917.21(A)(7) — 3 cases
Grace v. Moneygram (N.D. Ohio 2022).
William Horner v. Cuyahoga Cnty., et al. (E.D. Tenn. 2026).
State v. Walker, 2022 Ohio 3849 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2917.21(A)(9) — 1 case
State v. Haney, 2026 Ohio 227 (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2917.21(B) — 43 cases
State v. Ellison, 900 N.E.2d 228 (Ohio Ct. App. 2008). “Ellison challenges her conviction for telecommunications harassment under R.C. 2917.21(B). We find merit to her appeal and reverse her conviction.”
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
State v. Ham, 2017 Ohio 9189 (Ohio Ct. App. 2017). “Specifically, the state requested that the telecommunications harassment charge be amended to reflect a violation of R.C. 2917.21(A)(5), which prohibits a person from continuing to make telecommunications after the recipient has told the caller to stop, instead of the (B)…”
State v. Combs, 2019 Ohio 190 (Ohio Ct. App. 2019).
In re C.W., 2019 Ohio 5262 (Ohio Ct. App. 2019). “And, R.C. 2917.21(B) does not require more than a single transmission.”
— Ohio Rev. Code § 2917.21(B)(1) — 22 cases
State v. Powell, 2020 Ohio 4283 (Ohio Ct. App. 2020). “Haines included in his text message the language from R.C. 2917.21, the telecommunications-harassment statute.”
In re C.W., 2019 Ohio 5262 (Ohio Ct. App. 2019). “And, R.C. 2917.21(B) does not require more than a single transmission.”
Crenshaw v. Howard, 2022 Ohio 3914 (Ohio Ct. App. 2022). “R.C. 2917.21 is a criminal statute. R.C. 2917.”
State v. Pleatman, 2016 Ohio 7659 (Ohio Ct. App. 2016).
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
— Ohio Rev. Code § 2917.21(B)(2) — 8 cases
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
State v. Brentley, 2023 Ohio 2530 (Ohio Ct. App. 2023). “As used under R.C. 2917.21(A), “‘[c]aller’” means the person * * * who makes or causes to be made a telecommunication or who permits a telecommunication to be made from a telecommunications device under that person’s control.”
State v. Levesque, 2025 Ohio 2834 (Ohio Ct. App. 2025).
State v. Smith, 2018 Ohio 5121 (Ohio Ct. App. 2018).
State v. Wagener, 2022 Ohio 724 (Ohio Ct. App. 2022).
— Ohio Rev. Code § 2917.21(B)(C)(1)(2) — 1 case
State v. Brazina, 2017 Ohio 7500 (Ohio Ct. App. 2017).
— Ohio Rev. Code § 2917.21(C) — 1 case
State v. Wagner, 608 N.E.2d 852 (Ohio Ct. App. 1992). “5: “The trial court erred in finding that repeated telephone calls to an answering machine constituted a violation of O.R.C. 2917.21.” We begin with the fifth assignment of error.”
— Ohio Rev. Code § 2917.21(C)(1) — 1 case
State v. Birch, 2020 Ohio 90 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2917.21(C)(2) — 9 cases
City of Cleveland Heights v. Lewis, 2011 Ohio 2673 (Ohio 2011).
State v. Salupo, 894 N.E.2d 746 (Ohio Ct. App. 2008). “” A violation of R.C. 2917.21 can be a felony of the fifth degree only if it is a subsequent offense.”
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
State v. Henry, 2023 Ohio 4020 (Ohio Ct. App. 2023).
State v. Beem, 2020 Ohio 2964 (Ohio Ct. App. 2020).
— Ohio Rev. Code § 2917.21(E)(3) — 3 cases
State v. Ellison, 900 N.E.2d 228 (Ohio Ct. App. 2008). “Ellison challenges her conviction for telecommunications harassment under R.C. 2917.21(B). We find merit to her appeal and reverse her conviction.”
In re C.W., 2019 Ohio 5262 (Ohio Ct. App. 2019). “And, R.C. 2917.21(B) does not require more than a single transmission.”
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
— Ohio Rev. Code § 2917.21(F) — 2 cases
State v. Pillar, 2012 Ohio 3926 (Ohio Ct. App. 2012).
Hicks v. Faris (S.D. Ohio 2024).
— Ohio Rev. Code § 2917.21(G)(2) — 4 cases
State v. Brentley, 2023 Ohio 2530 (Ohio Ct. App. 2023). “As used under R.C. 2917.21(A), “‘[c]aller’” means the person * * * who makes or causes to be made a telecommunication or who permits a telecommunication to be made from a telecommunications device under that person’s control.”
State v. Shuck, 2020 Ohio 6989 (Ohio Ct. App. 2020). “7 {¶15} Although none of the individual terms “abuse,” “threaten,” or “harass” have been statutorily defined within the meaning of R.C. 2917.21, “‘[t]he fact that the statute does not place legal definitions on each of these terms demonstrates that the General Assembly intended…”
State v. DiSabato, 2019 Ohio 3542 (Ohio Ct. App. 2019).
State v. Montgomery (Ohio Ct. App. 2026).
— Ohio Rev. Code § 2917.21(G)(3) — 2 cases
State v. Shuck, 2020 Ohio 6989 (Ohio Ct. App. 2020). “7 {¶15} Although none of the individual terms “abuse,” “threaten,” or “harass” have been statutorily defined within the meaning of R.C. 2917.21, “‘[t]he fact that the statute does not place legal definitions on each of these terms demonstrates that the General Assembly intended…”
Plunderbund Media L.L.C. v. DeWine, 312 F. Supp. 3d 654 (N.D. Ohio 2018). “) Ohio Rev. Code § 2917.21, provides, in relevant part: (F) Divisions (A)(5) to (11) and (B)(2) of this section do not apply to a person who, while employed or contracted by a newspaper, magazine, press association, news agency, news wire service, cable channel or cable…”
— Ohio Rev. Code § 2917.21(H) — 1 case
Hicks v. Faris (S.D. Ohio 2024).
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.