Doe v. Flair Corp.’s Empirical Analysis

Citation profile

7 state decisions

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 7 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. ““ ‘In order to establish a claim for negligence, a plaintiff must establish a duty owed by the defendants, a breach of that duty which proximately results in an injury. Jeffers v. Olexo (1989), 43 Ohio St.3d 140, 142 [ 539 N.E.2d 614, 616-617 ]. As a general rule, landlords have no duty to protect their tenants from the criminal acts of third persons. Thomas v. Hart Realty, Inc. (1984), 17 Ohio App.3d 83, 86 [17 OBR 145, 147, 477 N.E.2d 668, 671 ]; Sciascia v. Riverpark Apts. (1981), 3 Ohio App.3d 164, 166 [3 OBR 188, 190-191, 444 N.E.2d 40, 42-43 ]; Johnson v. Monroe Realty Co. (May 25, 1995), Cuyahoga App. No. 67964, unreported [ 1995 WL 322278 ]. The duty of a landlord in such cases was set forth in Carmichael v. Colonial Square Apartments (1987), 38 Ohio App.3d 131 [ 528 N.E.2d 585 ]. Carmichael dealt with a tenant who had been assaulted in his own apartment and brought suit against his landlord alleging that he was negligent in failing to provide adequate security in the common areas of the building. The court determined that the landlord had complied with his duty to provide reasonable security: “ ‘* * * while the landlord has some duty to provide secure common areas in an apartment complex, he is not an insurer of the premises against criminal activity. * * * Thus, the duty on the landlord is only to take some reasonable precautions to provide reasonable security. “ ‘Id. at 132 [ 528 N.E.2d at 586-587 ]. See, also, Kelly v. Bear Creek Invest. Co. (Feb. 14, 1991), Cuyah”

   1 later decision quote this exact passage
   e.g. 138 Ohio App. 3d 476 - Sayles v. Sb-92 Ltd. Partnership

2. ““In order to establish a claim for negligence, a plaintiff must establish a duty owed by the defendants, a breach of that duty which proximately results in an injury. Jeffers v. Olexo (1989), 43 Ohio St.3d 140, 142 , 539 N.E.2d 614, 616-617 . As a general rule, landlords have no duty to protect their tenants from the criminal acts of third persons. Thomas v. Hart Realty, Inc. (1984), 17 Ohio App.3d 83, 86 , 17 OBR 145, 147, 477 N.E.2d 668, 671 ; Sciascia v. Riverpark Apts. (1981), 3 Ohio App.3d 164, 166 , 3 OBR 188, 190-191, 444 N.E.2d 40, 42 [-43]; Johnson v. Monroe Realty Co. (May 25, 1995), Cuyahoga App. No. 67964, unreported, 1995 WL 322278 . The duty of a landlord in such cases was set forth in Carmichael v. Colonial Square Apartments (1987), 38 Ohio App.3d 131 , 528 N.E.2d 585 . Carmichael dealt with a tenant who had been assaulted in his own apartment and brought suit against his landlord alleging that he was negligent in failing to provide adequate security in the common areas of the building. The court determined that the landlord had complied with his duty to provide reasonable security: “ ‘ * * * while the landlord has some duty to provide secure common areas in an apartment complex, he is not an insurer of the premises against criminal activity. * * * Thus, the duty on the landlord is only to take some reasonable precautions to provide reasonable security.’ Id. at 132 , 528 N.E.2d at 586 .”

   1 later decision quote this exact passage
   e.g. 136 Ohio App. 3d 573 - Doe v. Beach House Development Company