Ohio Case Commentaries

PUCO Prudency Reviews: Must-Run Strategy Judged Without Hindsight; Subpoenas Discretionary; Auditor Independence Requires “Undue Influence,” Not Mere Appearance

Date: Apr 29, 2026

PUCO Prudency Reviews: Must-Run Strategy Judged Without Hindsight; Subpoenas Discretionary; Auditor Independence Requires “Undue Influence,” Not Mere Appearance I. Introduction Case: In re Rev. of...

2026-Ohio-1471: Summary Dispositions and Procedural Orders—No New Substantive Precedent, but Clear Signals on Mootness and Gatekeeping

Date: Apr 29, 2026

2026-Ohio-1471: Summary Dispositions and Procedural Orders—No New Substantive Precedent, but Clear Signals on Mootness and Gatekeeping Court: Supreme Court of Ohio Date: April 28, 2026 Citation:...

Penn Central “Investment-Backed Expectations” Must Track Known Regulatory Risk—Agency “Stonewalling” Does Not Create a Taking

Date: Apr 29, 2026

Penn Central “Investment-Backed Expectations” Must Track Known Regulatory Risk—Agency “Stonewalling” Does Not Create a Taking Case: State ex rel. AWMS Water Solutions, L.L.C. v. Mertz, Slip Opinion...

In re L.E.S. (2026-Ohio-1449): R.C. 3111.95(A) Cannot Be Retroactively Extended to Unmarried Same-Sex Partners via a “Would Have Been Married” Test

Date: Apr 29, 2026

In re L.E.S. (2026-Ohio-1449): R.C. 3111.95(A) Cannot Be Retroactively Extended to Unmarried Same-Sex Partners via a “Would Have Been Married” Test 1. Introduction In re L.E.S., E.S., and N.S. is an...

Ordinary Lawn Maintenance Is Not “Open and Notorious” Enough to Start Ohio’s 21-Year Adverse-Possession Clock

Date: Apr 27, 2026

Ordinary Lawn Maintenance Is Not “Open and Notorious” Enough to Start Ohio’s 21-Year Adverse-Possession Clock 1. Introduction In NC Ents., L.L.C. v. Norfolk & W. Ry. Co., Slip Opinion No....

Fair-Notice and Context Rule for Public-Records Requests Embedded in Administrative Grievances (Ohio)

Date: Apr 24, 2026

Fair-Notice and Context Rule for Public-Records Requests Embedded in Administrative Grievances (Ohio) Introduction In State ex rel. Howard v. Chief Inspector's Office, Slip Opinion No....

R.C. 2953.21 Is the Exclusive Vehicle for Collateral Attacks: Civ.R. 60(B) Cannot Reopen Postconviction Judgments

Date: Apr 24, 2026

R.C. 2953.21 Is the Exclusive Vehicle for Collateral Attacks: Civ.R. 60(B) Cannot Reopen Postconviction Judgments I. Introduction State v. Hill, Slip Opinion No. 2026-Ohio-1427 (Supreme Court of...

State v. J.B. (2026-Ohio-1405): Trial Courts May Weigh Number/Nature of Convictions and Governmental Interests Sua Sponte When Deciding Sealing Under R.C. 2953.32

Date: Apr 24, 2026

State v. J.B. (2026-Ohio-1405): Trial Courts May Weigh Number/Nature of Convictions and Governmental Interests Sua Sponte When Deciding Sealing Under R.C. 2953.32 1. Introduction In State v. J.B.,...

Third-Party Electric Submetering Providers Are “Electric Light Companies” (Public Utilities) Under R.C. 4905.03(C)

Date: Apr 24, 2026

Third-Party Electric Submetering Providers Are “Electric Light Companies” (Public Utilities) Under R.C. 4905.03(C) 1. Introduction Case: In re Complaint of Ohio Power Co. v. Nationwide Energy...

Strict-Compliance Rule: Inmate Affidavits Must List Every Party in Every Prior Civil Action Under R.C. 2969.25(A)(3)

Date: Apr 16, 2026

Strict-Compliance Rule: Inmate Affidavits Must List Every Party in Every Prior Civil Action Under R.C. 2969.25(A)(3) 1. Introduction State ex rel. Bates v. Copley, 2026-Ohio-1270 is a Supreme Court...

Electronically Soliciting a Client’s Significant Other for Sex as Prof.Cond.R. 8.4(h) Misconduct; Actual Two-Year Suspension for Combined Neglect, Dishonesty, and Noncooperation

Date: Apr 16, 2026

Electronically Soliciting a Client’s Significant Other for Sex as Prof.Cond.R. 8.4(h) Misconduct; Actual Two-Year Suspension for Combined Neglect, Dishonesty, and Noncooperation I. Introduction In...

Mandatory R.C. 3503.24(B) Hearing When Records Are Insufficient; Statewide Elector Standing and Limited Res Judicata in Voter-Registration Challenges

Date: Apr 16, 2026

Mandatory R.C. 3503.24(B) Hearing When Records Are Insufficient; Statewide Elector Standing and Limited Res Judicata in Voter-Registration Challenges 1. Introduction State ex rel. Hicks v. Adams Cty....

Jones v. Galloway: Improper Judicial Assignment Creates a Voidable Error (Not a Void Judgment) and Inmates Must Strictly Comply with R.C. 2969.25(A) in Habeas Filings

Date: Apr 16, 2026

Jones v. Galloway: Improper Judicial Assignment Creates a Voidable Error (Not a Void Judgment) and Inmates Must Strictly Comply with R.C. 2969.25(A) in Habeas Filings 1. Introduction In Jones v....

Mandamus Cannot Be Used to Vacate a Conviction by Compelling a Municipal-Court Clerk; Adequate Remedy by Appeal Bars the Writ

Date: Apr 16, 2026

Mandamus Cannot Be Used to Vacate a Conviction by Compelling a Municipal-Court Clerk; Adequate Remedy by Appeal Bars the Writ I. Introduction In State ex rel. Wright v. Clerk of Mun. Court, Slip...

State v. Seymour: But-For Causation in Mixed-Drug Overdose Cases Does Not Require the Defendant’s Drug to Be the Sole Cause

Date: Apr 16, 2026

State v. Seymour: But-For Causation in Mixed-Drug Overdose Cases Does Not Require the Defendant’s Drug to Be the Sole Cause 1. Introduction State v. Seymour (Supreme Court of Ohio, 2026-Ohio-1249)...

State v. Fips (2026-Ohio-1207): License-Status Checks Are Part of a Traffic Stop’s Mission Even After the Original Suspicion Is Dispelled

Date: Apr 9, 2026

State v. Fips (2026-Ohio-1207): License-Status Checks Are Part of a Traffic Stop’s Mission Even After the Original Suspicion Is Dispelled Court: Supreme Court of Ohio | Date: April 7, 2026 |...

Crim.R. 33 Motions Must Be Ruled on Sequentially; Mandamus Lies to Compel a Long-Delayed Ruling on Leave, Not on the New-Trial Motion Itself

Date: Apr 9, 2026

Crim.R. 33 Motions Must Be Ruled on Sequentially; Mandamus Lies to Compel a Long-Delayed Ruling on Leave, Not on the New-Trial Motion Itself Case: State ex rel. Quinn v. Rastatter, Slip Opinion No....

R.C. 2969.25(A)(2) Strict-Compliance Rule: Inmates Must List Case Numbers for Both Prior Civil Actions and Appeals (“Or” Is Inclusive)

Date: Apr 9, 2026

R.C. 2969.25(A)(2) Strict-Compliance Rule: Inmates Must List Case Numbers for Both Prior Civil Actions and Appeals (“Or” Is Inclusive) I. Introduction In State ex rel. Stokes v. Combs, Slip Opinion...

April 8, 2026 Supreme Court of Ohio Case Announcements: Disposition Notices, Conflict Certification, and Extraordinary-Writ Gatekeeping

Date: Apr 9, 2026

April 8, 2026 Supreme Court of Ohio Case Announcements: Disposition Notices, Conflict Certification, and Extraordinary-Writ Gatekeeping Introduction The document titled 04/08/2026 Case Announcements,...

Hoskins v. Cleveland: “Physical Defect” Under R.C. 2744.02(B)(4) Requires a Tangible Imperfection, Not a Lifeguard’s Seating Choice

Date: Apr 9, 2026

Hoskins v. Cleveland: “Physical Defect” Under R.C. 2744.02(B)(4) Requires a Tangible Imperfection, Not a Lifeguard’s Seating Choice 1. Introduction In Hoskins v. Cleveland, Slip Opinion No....