153 Ohio App. 3d 88 - State v. Orwick’s Empirical Analysis

Citation profile

5 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 5 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

1. “Nothing in * * * R.C. 2317.02 supports the State's characterization of the exception at issue here as a sweeping waiver providing unbridled disclosure. Those cases dealing with the breadth of exceptions to statutory privileges generally limit the scope of disclosure to communications falling within the confines of the exception to the privilege. The mere fact that some statements are excepted from the privilege does not compel disclosure of all of a defendant's confidential communications to his counselor, physician, or therapist. Limited disclosure is appropriate as to the statements which triggered a warning required by a compelled reporting statute or communications providing indicia of a clear and present danger to the client or other persons. Although the privilege is to be narrowly construed, we are not willing to broaden [the] scope of an exception where the remaining communications fall squarely with the purviews of the statute.”

   1 later decision quote this exact passage
   e.g. State v. Dunn, Unpublished Decision (9-4-2005)