13 Ohio App. 3d 37 - In Re Sims’s Empirical Analysis
1983
Citation profile
62 state decisions
How this case has been cited
Cited by 62 later decisions — most recently February 2026 · most notably 83 Ohio App. 3d 869 - In Re Brofford (1992), In Re Alexander C. (2005)
62 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 Santosky v. Kramer · In re Cunningham · 70 Ohio App. 2d 117 - In Re Bibb · In re East · In re Hunt
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 62 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“[W]here a trial judge acts as the fact finder, a reviewing court will be slow to overturn an adjudication on the basis *Page 8 of the admission of inadmissible testimony, unless it appears that the court below actually considered such testimony in arriving at its judgment, as the trial judge is presumed capable of disregarding improper testimony.”
2 later decisions quote this exact passage · from the majority“allege the particular facts upon which the allegation that the child is a delinquent child or a juvenile *Page 7 traffic offender is based.”
2 later decisions quote this exact passage · from the majority“'Informality' [in juvenile court proceedings] does not mean abandoning the procedural and evidentiary rules which guide a court in search of the truth. Indeed, where one's fitness as a parent is being attacked by the state, where a potential end result is the loss of custody of one's child, and where the adjudication will be based on the resolution of conflicting testimony, the emphasis should be on an accurate search for the truth and not on informality. "The hearsay rule is based, primarily, on the fact that one against whom the hearsay is offered has no opportunity to cross-examine the person with first-hand knowledge to determine whether that witness accurately perceived the event, retained an accurate impression of what he perceived, and is able to convey the perceived data without error. See, generally, McCormick, Evidence (2d Ed. Cleary Ed. 1972) 581, Section 245. While Juv. R. 29 permits an adjudicatory hearing to be 'informal,' a father or mother defending his or her fitness as a parent in an adversarial and often highly emotional proceeding should not have less protection than a defendant in small claims court. The importance of the parental interests involved demands an accurate determination of the facts surrounding a complaint alleging neglect or dependency and requires substantial compliance with the Rules of Evidence. ***”
1 later decision quote this exact passage · from the majoritye.g. In re Vickery
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.