State v. Consilio’s Empirical Analysis
2007
Citation profile
124 state decisions
How this case has been cited
Cited by 126 later decisions — most recently October 2025 · most notably State v. Williams (2011), In re A.J.S. (2008)
124 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Relies on Van Fossen v. Babcock & Wilcox Co. · State v. Williams · 87 Ohio St. 3d 350 - Bielat v. Bielat · Brennaman v. R.M.I. Co. · State ex rel. Plain Dealer v. Ohio Dept. of Insurance
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 126 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[t]he General Assembly's failure to clearly enunciate retroactivity ends the analysis, and the relevant statute may be applied only prospectively.”
5 later decisions quote this exact passage“{¶ 28} “It is well-settled law that statutes are presumed to apply prospectively unless expressly declared to be retroactive. R.C. 1.48; Van Fossen v. Babcock Wilcox Co. (1988), 36 Ohio St.3d 100, 105 , 522 N.E.2d 489 . It is also settled that the General Assembly does not possess an absolute right to adopt retroactive statutes. Section 28, Article II of the Ohio Constitution prohibits the retroactive impairment of vested substantive rights. See State v. LaSalle, 96 Ohio St.3d 178 , 2002-Ohio-4009 , 772 N.E.2d 1172 , ¶ 13. However, the General Assembly may make retroactive any legislation that is merely remedial in nature. See State ex rel. Slaughter v. Indus. Comm. (1937), 132 Ohio St. 537, 542 , 8 O.O. 531 , 9 N.E.2d 505 .” (Plurality opinion.) Id. at ¶ 9.”
3 later decisions quote this exact passage“A statute must clearly proclaim its own retroactivity to overcome the presumption of prospective application. Retroactivity is not to be inferred.”
3 later decisions quote this exact passage
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.