21 Ohio App. 3d 31 - In Re Smart’s Empirical Analysis
1984
Citation profile
22 state decisions
How this case has been cited
Cited by 22 later decisions — most recently July 2021
22 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 In re Cunningham · 147 Ohio St. 416 - Weis v. Weis · In re East · In re Miller · 59 Ohio App. 2d 78 - In Re Justice
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 22 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
““Even though a' juvenile court does have the alternative immediately to grant permanent custody to an appropriate state agency upon determination that a child is abused, neglected or dependent under R.C. 2151.353(A)(4), permanent custody should only be granted at the initial disposition hearing under extreme situations where reunification is not possible. Specifically, a court cannot reach the determination under R.C. 2151.353(A)(4) that ‘the child will continue to be a child without adequate parental care if a reunification plan were prepared’ where there has been no good faith effort to reunite the child with his parents or evidence that such an effort to reunite would be futile.””
2 later decisions quote this exact passage““As used in Sections 2151.01 to 2151.54, inclusive, of the Revised Code, ‘dependent child’ includes any child: “(A) Who is homeless or destitute or without proper care or support, through no fault of his parents, guardian, or custodian; “(B) Who lacks proper care or support by reason of the mental or physical condition of his parents, guardian, or custodian; “(C) Whose condition or environment is such as to warrant the state, in the interests of the child, in assuming his guardianship.””
1 later decision quote this exact passage“failure by [the agency] to file a comprehensive reunification plan does not bar its action for immediate permanent commitment under R.C. 2151.353(A)(4).”
1 later decision quote this exact passagee.g. In re B.B.
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.