124 Ohio App. 3d 40 - State v. Hirtzinger’s Empirical Analysis
1997
Citation profile
43 state decisions
How this case has been cited
Cited by 43 later decisions — most recently January 2026 · most notably John Soliday Financial Group, L.L.C. v. Pittenger (2010), State v. Hood (2012)
43 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 State v. Thompkins · State v. Jenks · 20 Ohio App. 3d 172 - State v. Martin · Tibbs v. Florida · State v. Edwards
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 43 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“testify as to the regularity and reliability of the business activity involved in the creation of the record.”
3 later decisions quote this exact passage“'it must be demonstrated that the witness is sufficiently familiar with the operation of the business and with the circumstances of the record's preparation, maintenance and retrieval, that he can reasonably testify on the basis of this knowledge that the record is what it purports to be, and that it was made in the ordinary course of business consistent with the elements of Rule 803(6).'”
1 later decision quote this exact passagee.g. State v. McDonald“When a court admits hearsay against the dictates of Evid.R. 802, the standard of review is a strict one. `In the final analysis, the evidence in favor of conviction absent the hearsay must be so overwhelming that the admission of those statements was harmless beyond a reasonable doubt.'”
1 later decision 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.