144 Ohio App. 3d 211 - Westfall v. Cross’s Empirical Analysis
2001
Citation profile
23 state decisions
How this case has been cited
Cited by 23 later decisions — most recently February 2026
23 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 AAAA Enterprises, Inc. v. River Place Community Urban Redevelopment Corp. · Leis v. Flynt · Bechtol v. Bechtol · State ex rel. Keenan v. Calabrese · Royal Indemnity Co. v. J. C. Penney Co.
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 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“The right of an out-of-state attorney to appear as counsel in an Ohio court is not an absolute right, but, rather, is a matter within the discretion of the trial court. Royal Indemn. Co. v. J.C. Penney Co. (1986), 27 Ohio St.3d 31, 33 , 27 OBR 447, 448-449, 501 N.E.2d 617, 619-620 . The right to confer or revoke pro hac vice status is “part of the court’s inherent power to regulate the practice before it and protect the integrity of its proceedings.” Id. at 33-34 , 27 OBR at 449, 501 N.E.2d at 620 . Gov.Bar R. I(9)(H) acknowledges this inherent power by stating that the rules governing the admission to the practice of law in Ohio do “not apply to participation by an attorney not yet admitted to practice in Ohio in a cause being litigated in the State when such participation is with leave of the judge hearing such case.” The right to appear as counsel pro hac vice is conferred by the common law and not by statute.”
2 later decisions quote this exact passage“(b) The appealing party would not be afforded a meaningful or effective remedy by an appeal following final judgment as to all proceedings, issues, claims, and parties in the action. {¶ 12}”
1 later decision quote this exact passage“(2) An order that affects a substantial right made in a special proceeding or upon a summary application in an action after judgment; {¶ 8}”
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.